[00:00:01]
MY NAME'S MATT MARINAS WITH WORKSHOP
[2. Review Workshop Purpose]
NUMBER ONE OF YET ANOTHER TOPIC FOR ERCOT.UH, THANK Y'ALL FOR BEING HERE.
THIS IS AN IMPORTANT, UM, IMPORTANT JUMPING OFF POINT FOR ERCOT.
AS YOU KNOW, UH, SENATE BILL SIX HAS HAD A LOT OF, UH, TOUCH POINTS INTO OUR OPERATIONS, THE WAY WE, UH, ADMINISTER OUR MARKETS, THE WAY WE PLAN FOR OUR MARKETS AND FUTURE CONNECTIONS.
AND TODAY WAS A CHANCE TO TALK ABOUT SPECIFICALLY THE LARGE LOAD CURTAILMENT.
UH, PART OF THAT STORY IS WHAT HAPPENS TODAY, UM, YOU KNOW, BEFORE LARGE LOADS.
THEN THERE'S THE LARGE LOADS WE HAVE TODAY, AND THEN THERE'S THE FUTURE LARGE LOADS.
SO IT'S DEFINITELY AN EVOLUTIONARY, UH, STORY OF WHERE WE'RE TRYING TO GET TO IN TERMS OF MATURING OUR PROCESSES.
AND AGAIN, ERCOT WANTS COLLABORATION ON THIS.
UH, SO HERE WE'RE ACTUALLY PRESENTING QUESTIONS TODAY AND, UM, YOU KNOW, WHERE THINGS DON'T SEEM TO QUITE ALIGN PERFECTLY YET AND WHAT THE NEXT STEPS ARE FOR THAT.
SO, IKA IS OUR, UM, SUBJECT MATTER IN THE LEADER IN THIS REALM.
I'M SUPPORTING HER FROM THE BACK ROW OVER HERE.
AND SO WHAT WE WANTED TO DO TODAY WAS TO, UH, WE POSTED A SET OF 30 SOMETHING SLIDES, UH, LAST NIGHT.
SO IKA AND I'LL BE FIGURING OUT WHEN TO PAUSE AND LET HER TELL THE STORY, AND THEN TO PAUSE AND TAKE QUESTIONS.
IF YOU HAVEN'T BEEN TO THE STAKEHOLDER MEETINGS OR YOU'RE ONLINE, UH, THE BEST WAY TO ASK A QUESTION, EVEN IF YOU'RE IN THE ROOM, IS JUST TO PLEASE PUT YOUR NAME INTO THE CHAT, UH, FEATURE OF WEBEX, AND THEN I'LL BE RUNNING THE QUEUE, UH, TO CALL PEOPLE AS THEY COME IN.
BUT AGAIN, REMINDER, WE DON'T USE THE RAISE HAND FEATURES, AND WE WILL GET TO YOUR QUESTION EVENTUALLY.
UH, AND THE GOAL IS TO STOP AT NOON.
UH, LAST THING IS, I WILL JUST THROW UP THE ANTITRUST ADMONITION, JUST A REMINDER OF HOW WE OPERATE AROUND HERE AND AVOIDING THOSE ANTITRUST ISSUES.
AND WITH THAT, I THINK THAT'S THE HOUSEKEEPING.
OTHERWISE, WE'LL GET IT GOING WITH NITKA.
I HOPE YOU CAN HEAR ME LOUD AND CLEAR ON THE MIC.
UH, SO AGAIN, THANK YOU MATT, FOR SETTING US UP.
AS MATT SAID, THIS IS PROBABLY THE FIRST OF A FEW WORKSHOPS THAT WE, UH, ARE LOOKING TO ENGAGE ON, UH, UH, SPECIFICALLY FOCUSED ON THIS TOPIC OF THE, THE CURTAILMENT PROVISIONS THAT WERE OUTLINED IN SB SIX.
UH, WHAT WE HAVE LAID, UH, HERE TODAY FOR YOU IS MORE OF A, UH, UH, IS MORE CONCEPTS STARTING OUT EXACTLY WHERE SP SIX, WHAT LANGUAGE WAS WRITTEN IN SB SIX, HOW WE SEE, UH, IT FIT IN OPERATIONS, WHAT SORT OF OPERATIONAL IMPLICATIONS, THE LANGUAGE AS WRITTEN MAY BRING, BRING IN.
AND THEN WHAT ARE THE POTENTIAL THINGS WE CAN DO.
UH, AS MATT ALSO MENTIONED THIS, REALLY THIS IS A CONVERSATION TOPIC.
THIS WE ARE HERE TO SHARE WHAT WE ARE SEEING AND HEAR PERSPECTIVE, HEAR YOUR FEEDBACK.
THE SECOND WORKSHOP IS ON THE CALENDAR TODAY, ALSO, UH, IT'S NOT IN MY SLIDE DECK, BUT THE NEXT WORKSHOP IS AVAILABLE SCHEDULED FOR NOVEMBER 6TH, SO EXACTLY A MONTH FROM NOW.
AND OUR HOPE IS TO, AS TODAY GOES, HEAR YOUR FEEDBACK, UH, UH, YOU KNOW, OF COURSE GIVE YOU ALL SOME TIME TO, TO ALSO DIGEST IN WHAT YOU HEAR.
IF ANYTHING COMES UP, PROVIDE US FEEDBACK SO WE CAN BUILD THE NEXT ROUND OF CONTENT, UH, AND COME SHARE THE CONVERSATION OR COME SHARE WHAT, WHERE WE HAVE LANDED.
OUR EVENTUAL GOAL IS TO, OF COURSE, FILE REVISION REQUESTS TO BRING SOME OF THIS LANGUAGE INTO THE PROTOCOLS, UH, THAT WILL HELP US IMPLEMENT SB SIX.
SO AT LEAST THAT'S OUR, UH, UH, THAT'S THE, AT LEAST THE IMMEDIATE NEAR GOAL IN OUR MIND IS BRING THIS WORK TO A POINT WHERE WE CAN FILE THOSE REVISION REQUESTS AND GET FORMAL FEEDBACK.
SO, AGAIN, THERE'S QUITE A BIT OF MATERIAL.
UH, WHAT WE'LL DO IS I'M GONNA WORK THROUGH THE BACKGROUND AND MAYBE EVEN THE REFRESHER SLIDES.
UH, AND I'LL PAUSE ALONG THE WAY TO SEE, UH, IF, IF THERE ARE QUESTIONS ON THOSE TWO.
BUT THEN, UH, IF POSSIBLE, LET'S START TO HAVE A, A DECENT CONVERSATION BY THE END OF THE REFRESHER MATERIALS.
AND THEN ONCE WE GET INTO THE DEEP DIVE, I WILL PAUSE THE QUESTIONS AND WE'LL SEE HOW, HOW FAR WE CAN TILL WE, SO WE CAN SHARE AT LEAST WHAT THAT DEEP DIVE IS ALL ABOUT.
SO WITH THAT, WITH THAT SETUP, I'LL GO AHEAD AND GET STARTED.
MAYBE IF I CLICK THE RIGHT BUTTONS.
ALRIGHT, SO LET'S START WITH SOME BACKGROUND.
SO THERE IS A, I MEAN, THIS GRAPHIC IS, I MEAN, THIS DATA IS PROBABLY NOT NEW TO YOU.
[00:05:01]
THE DATA THAT, UH, UH, JEFF HAD PRESENTED AT OUR LAST BOARD MEETING AROUND THE BATCH ZERO PROCESS AND THE TYPE OF VOLUME OF LARGE LOADS WE ARE SEEING.ERCOT IS SEEING SIGNIFICANT LARGE VOLUMES OF LARGE LOADS PURSUING INTERCONNECTIONS WITHIN THE ERCOT REGIONS.
AS THESE LOADS ARE ADDED, GENERATION MAY NOT ALWAYS KEEP PACE, UH, WITH, UH, WITH THE SYSTEM DEMAND AND FORESEEING THIS RISK.
THE, THE LEGISLATURE CREATED NEW AUTHORITY IN SB SIX TO DIRECT CURTAILMENT OF CERTAIN LARGE LOAD.
WE ARE ALREADY, THE BATCH ZERO, UH, BASE LOAD NUMBERS ARE SOMEWHERE IN THE 50 GIGAWATT RANGE.
OF COURSE, THESE ARE SUBJECT TO VERIFICATION, BUT, UM, EVEN WITHIN TWO YEARS, THE, THE ANTICIPATED LOAD GROWTH IS QUITE DRASTIC.
NOW, THIS PARTICULAR GRAPHIC, WHAT WE PUT TOGETHER HERE WAS THE VARIOUS LOAD REDUCTION MECHANISMS THAT ARE ALREADY IN OUR CURRENT RULES.
AND WHAT MAY GET ADDED AFTER SB SIX IS ACCOUNTED FOR.
SO WHAT'S EXISTING? THINGS LIKE, UH, CONTROLLABLE LOAD RESOURCES, THESE ARE REGISTERED RESOURCES.
THEY ARE, UH, THEY GET DISPATCHED BY SC NPR AT 1238.
CREATED VOLUNTARY EARLY CURTAILMENT LOADS.
THESE LOADS CAN BE CURTAILED WITH A 30 MINUTE NOTICE WHEN OPERATING MARGIN FALLS BELOW 3,100 MEGAWATTS, OR PRC FALLS BELOW 300 3100 MEGAWATTS ERS.
UH, IT'S A PRODUCT THAT, UH, LOADS CAN PROVIDE, UH, WITH 10 MINUTE RESPONSE, 30 MINUTE RESPONSE, USUALLY DEPLOYED IN ANY EA OR AN ENERGY EMERGENCY ALERT, LEVEL ONE NC LRS.
THESE RESOURCES PROVIDE SEVERAL AS, UH, CAN QUALIFY TO PROVIDE SEVERAL AS.
UM, THE, THE KEY, UH, UH, PARTICIPATION IN, IN RRS AND ECRS IS THE ONE THAT DEPLOYS WITH A 10 MINUTE RESPONSE, TYPICALLY, UH, WHEN WE ARE IN AN EEA TWO.
AND I'LL GIVE YOU A REFRESHER ON WHAT THESE LEVELS ARE HERE, HERE IN A MINUTE.
NOW, WHAT DID SP SIX DO? IT ADDED THREE DIFFERENT TYPES OF, UH, CURTAIL LEVEL CLASSES.
NET METERED, CURTAIL LEVEL LOAD IS ONE, UH, BACKUP SUPPORTED CURTAIL LEVEL LOAD IS ANOTHER.
AND LARGE LOAD DEMAND MANAGEMENT SERVICES IS THE THIRD.
NOW THE FIRST TWO TERMS, UH, IF YOU'VE BEEN READING SB SIX, THEY ARE NOT IN SB SIX.
SO, UH, SO, UH, SO I'LL, I'LL EXPLAIN.
I'M USING THE OPPORTUNITY TO ALSO COME UP WITH CONSISTENT TERMS THAT YOU, WE MAY USE WHEN WE DRAFT OUR OWN LANGUAGE.
SO WHAT IS NET METER CURTAIL LEVEL LOAD WITHIN, WITHIN THE SP SIX LANGUAGE? THESE ARE LOADS WHO HAVE A NET METERING ARRANGEMENT WITH AN EXISTING GENERATION RESOURCE OR ENERGY STORAGE RESOURCE.
THEY ARE SUBJECT TO CURTAILMENT UNDER CONDITIONS DIRECTED BY THE PUC.
SO, UH, WE RECOMMENDED COINING THE TERM NMCL NET METER CURTAIL LEVEL LOADS TO REFER TO THEM.
THE BACKUP SUPPORTED CURTAIL LEVEL LOAD IS LOAD THAT IS, UH, SUBJECT TO CURTAILMENT BECAUSE IT IS CAPABLE OF BEING SERVED BY ONSITE BACKUP GENERATION.
AT LEAST 50% OF THE DE DEMAND OF THE FACILITY CAN BE SERVED, UH, WITH THESE ONSITE BACKUP.
SO THESE WOULD BE LARGE LOADS THAT ARE ALSO SUBJECT TO CURTAILMENT.
AND THIS IS ONE CATEGORY BACKUP SUPPORTED CURTAIL LOAD THAT WE'LL SPEND A LOT OF TIME ON IN TODAY'S DECK.
'CAUSE WE DO WANT TO TRY AND SHARE WHAT SPECIFIC LANGUAGE WAS WRITTEN FOR THEM, UH, IN PURA, AND WHAT ARE THE OPERATIONAL IMPLICATIONS OF THAT LANGUAGE.
LASTLY, THERE'S A, A, A PAID SERVICE THAT SB SIX ALSO TEMPLATED WITH THE 24 HOUR NOTICE.
UM, I'M GONNA USE THE NEXT SLIDE.
SO WHAT IS THE FOCUS FOR TODAY AND WHAT, UH, AND WHAT ARE WE, WHAT IS THE SCOPE? SO WE'VE SAID IT NOW A FEW TIMES, BUT, UH, WE ARE AT LEAST THE, IN THROUGH THESE WORKSHOPS LOOKING TO SPEND TIME TALKING ABOUT THE SPECIFIC CURTAILMENT RELATED, UH, CONSTRUCTS WITHIN SB SIX.
SO, OPERATIONAL CONSIDERATIONS FOR IMPLEMENTING BACKUP SUPPORTED CURTAIL LEVEL LOAD, UH, AND, UH, AND RELEVANT OPERATIONAL TOPICS FOR NET METER CURTAIL LOAD, AND EVEN VEHICLES OR VOLUNTARY CURTAILMENT, EARLY CURTAILMENT LOADS.
WHAT WE ARE NOT LOOKING TO FOCUS ON AT LEAST INTENTIONALLY WITH THROUGH OUR WORKSHOPS, UH, ON THIS TOPIC IS, ARE THINGS LIKE CONTROLLABLE LOAD RESOURCES.
THE ERS SERVICE ITSELF, EVEN THE SB SIX, UH, PAID SERVICE IS NOT, UH, A FOCUS OF OUR, UH, FOR, FOR US AT LEAST, AN INTENTIONAL FOCUS.
RIGHT NOW, IT'S A SEPARATE CONVERSATION.
[00:10:03]
AND OUR GOAL IS TO DEVELOP A LARGE LOAD CURTAILMENT FRAMEWORK THAT CAN MAINTAIN RELIABILITY, ALIGN WITH THE PRINCIPLES THAT ARE WITHIN SP SIX AND SUPPORT REVISION REQUESTS NEEDED TO IMPLEMENT THOSE RESULTING DESIGNS.SO ULTIMATELY, LIKE I MENTIONED, OUR HOPE IS OUR GOAL IS TO BE ABLE TO DRAFT REVISION REQUESTS AND PUT THEM INTO THE PROCESS SO YOU ALL CAN FORMALLY OPINE ON THEM.
ALL RIGHT, SO AGAIN, THIS PARTICULAR SLIDE WE PUT OUT HERE JUST TO AGAIN, UH, HIGHLIGHT THAT THESE ARE REALLY THE TWO TYPES OF, UH, THE RESOURCES OR TWO TYPES OF ACTIONS THAT SB SIX CONTEMPLATED AS FAR AS CURTAILING LARGE LOADS, UH, GOES.
UH, I I WILL NOT SPEND TIME READING BOTH OF THESE MATERIALS, BUT NET METER CURTAIL LOADS, UH, THESE ARE LOADS THAT, UH, HAVE CONDITIONS IMPOSED ON THEM.
THERE ARE, UH, UH, TWO DATE PUC HAS APPROVED ABOUT THREE NET METERING PROJECTS.
THE CONDITIONS THAT THE PUC HAS, UH, PUT ON THEM ARE SUBSTANTIALLY SIMILAR.
CURTAILMENTS CAN BE INSTRUCTED IN ANTICIPATION OF AN EMERGENCY DURING AN EMERGENCY, OR TO AVOID AN EMERGENCY.
THE INSTRUCTION GOES TO THE QSC OF THE CO-LOCATED RESOURCE.
THE LOAD MUST FULLY CURTAIL WITHIN 30 MINUTES OF GETTING THE INSTRUCTION.
BACKUP SUPPORTED CURTAIL LEVEL LOAD IS DIFFERENT.
ITS LANGUAGE, UH, UH, IS, UH, ACTIONS RELATED TO THIS, UH, PARTICULAR GRASS OF LOADS IS VARIED CLEARLY, UH, VERY CLEANLY SPECIFIED.
WITHIN THE LOCK THAT PURA HAS WRITTEN, IT SPECIFIES THAT WE MAY DIRECT THE UTILITY TO CURTAIL, UH, B SCLS OR BACKUP SUPPORTED LOADS.
AFTER ALL AVAILABLE MARKET SERVICES HAVE BEEN DEPLOYED EXCEPT FOR FREQUENCY SERVICES.
SO I MENTIONED AS I STARTED THE PROCESS BSCL, OUR BACKUP SUPPORTED CURTAIL LEVEL LOAD IS WHERE WE WANT TO SPEND MOST OF OUR TIME TODAY TALKING WITH YOU ON.
BEFORE I GET TO THAT THOUGH, I WANT TO FIRST PAUSE.
I'VE USED WORD TERMS CALLED EEA LEVEL ONE, LEVEL TWO, LEVEL THREE.
I JUST WANNA GO AHEAD AND START WITH THE REFRESHER ON WHAT AN EEA IS AND THEN GET INTO THE DEEP DIVE.
UH, BILL, I SAW A QUESTION CAME THROUGH IS WILL, YEAH, BILL BARNES HAS A QUICK QUESTION.
SORRY, MAN, I DIDN'T, IS THAT GOOD? FOLLOW THE INSTRUCTIONS PROPERLY AND TYPE IT IN QUESTION.
NETIKA ON THE PRICING IMPACTS YES.
UM, I'M CURIOUS IF YOU GUYS HAVE MORE DETAILS OR CAN SHARE MORE DETAILS LATER ON HOW YOU PLAN TO IMPLEMENT THE PRICE ADJUSTMENT MECHANISM FOR BOTH OF THESE.
WE WERE JUST LOOKING AT THE VECL AND THAT PRICE ADJUSTMENT USES WHAT I WOULD CONSIDER AN OUTDATED PRICE RANGE OF 300 TO 700 MEGAWATTS LINEAR.
I I'M CONFIDENT THAT LARGE LOADS THE, THE, THE PRICE THAT, UH, THEY WOULD BE CURTAILING AS MUCH HIGHER THAN THAT.
SO I'M JUST WONDERING IF YOU'VE THOUGHT ABOUT HOW THESE WOULD WORK AND IF YOU WOULD USE A SIMILAR CONSTRUCT OR SOMETHING DIFFERENT.
SO TODAY IS NOT ABOUT THAT LEVEL OF DETAILS, BUT I WILL TAKE A NOTE WHEN WE COME BACK NEXT TIME.
WE WILL SPEND TIME TALKING ABOUT HOW THESE WILL BE ACCOUNTED FOR, UH, OR WHAT WE ARE THINKING, UH, IN, I'LL, I'LL LEAVE YOU WITH, AT LEAST TO THE EXTENT THAT PRICING IMPACT IS INVOLVED FOR B SCLS, THERE IS SOME GUIDANCE WITHIN THE PURE LAW THAT WAS WRITTEN.
I, FOR, TO THE OTHERS WHO'VE HELD BACK ON QUESTIONS, I WILL, IF IT'S OKAY, I'M GONNA KEEP GOING TO THE EEA SECTION AND THEN PAUSE AND TAKE QUESTIONS, RIGHT? SO NOW LET'S GO TO, LET'S START WITH WHERE I SAID LET'S TALK ABOUT E UH, WHAT AN E EEA IS, AND THEN HOW SP SIX CURTAILMENT FITS WITHIN IT.
SO, ENERGY EMERGENCY ALERT LEVELS ARE, UH, UH, ARE LEVELS THAT ARE COINED WITHIN THE PROTOCOLS.
UH, AND THEY ARE EFFECTIVELY, UH, WAYS THAT ERCOT STARTS COMMUNICATING.
WHEN IT IS EXPERIENCING TIGHT OPERATING CONDITIONS.
SO WHEN IN REAL TIME OPERATING MARGIN STARTS DECLINING AND DROPS BELOW 2,500 MEGAWATTS, UH, DECLARES EEA LEVEL ONE, WHEN THOSE RESERVE MARGINS DROP BELOW 2000, WE DECLARE AN EEA LEVEL TWO.
AND WHEN THOSE RESERVES ARE AT 1500 MEGAWATTS, WE DECLARE AN EEA LEVEL THREE AND MAY, UH, IN, IN INITIATE FIRM LOAD SHED
[00:15:01]
NOW.SO AGAIN, THE OPERATIVE WORD IS THESE ARE THINGS AS THEY HAPPEN IN REAL TIME WHEN OPERATE, WHEN THE MARGIN IS LOW, THEN WE TAKE THIS ACTION.
SO THIS IS ACTUAL, UH, CONDITIONS IN REAL TIME.
UH, WHAT ELSE CAN WE SAY ABOUT THIS? SO LET'S, UH, SO I'M GONNA, I'M GONNA MOVE ON AND COME BACK AND MAKE THE NEXT POINT.
NOW, WHAT HAPPENS TO WITH SP SIX, TO THESE EEA LEVELS? AS I MENTIONED, AT LEAST FOR NET METERED, CURTAIL LOADS, THE COMMISSION RULES GIVE, UH, CART THE ABILITY TO INSTRUCT CURTAILMENT WHEN WE EXPECT, OR WHEN WE ANTICIPATE, UH, OPERATING, UH, MARGIN BASED OFF OF NEAR TERM FORECASTS TO INDICATE THAT, UH, WE WILL BE ENTITLED TO OPERATING CONDITIONS.
SO WHEN OUR FORECAST, UH, INDICATE THAT OUR OPERATING MARGINS CAN PRODUCE, WE CAN INITIATE INSTRUCTION, UH, CURTAILMENT OF THESE NET METER LOADS TO AVOID ENTERING ANY EA.
AND OF COURSE, UH, UH, WE CAN DO, UH, WE CAN DO INSTRUCT THEM DURING AN EEA, ALSO THE BEST PLACE FOR THEM BASED OFF OF THE, OUR CURRENT PO UH, CURRENT POSTURE.
WHEN IT COMES TO TREATING, UH, BRINGING GENERATION ONLINE, ALL GENERATION ONLINE, IT OCCURS AT E EEA LEVEL ONE.
SO THAT'S, IT'S THAT PARTICULAR SE UH, LEVEL IS LINED UP WITH SOME OF OUR NERC REQUIREMENTS, UH, WHERE NERC ALSO INSISTS THAT WE, WHEN WE DECLARE EA ONE, THAT'S THE LEVEL WHERE WE BRING ALL AVAILABLE GENERATION, UH, TO BE, WE INSTRUCT ALL AVAILABLE GENERATION TO BE ONLINE.
SO AT LEAST THE TWO IN OUR MINDS, THE RIGHT PLACE FOR AN MCL WOULD BE NO LATER THAN EEA ONE.
AS FAR AS BACKUP SUPPORTED, CURTAIL LEVEL LOADS GO, UH, ANCHORING ON THE LANGUAGE THAT'S WRITTEN WITHIN PURE TODAY, THESE, UH, LOADS ARE, UH, UH, ARE, UH,
AND THAT TYPICALLY FOR US IS SOMEWHERE AROUND THAT OPERATING MARGIN OR WHEN OUR OPERATING MARGIN IS AROUND 2000 MEGAWATTS.
SO, SO YOU, YOU HEAR ME, UH, THERE'S A CAUTIOUS FRAMING ABOUT THIS.
THE BSCL CURTAILMENT COULD ALIGN WITH EEA TWO.
NOW ALL OF THIS WORKS, UH, OR THIS SORT OF AN APPROACH OF WAITING TILL YOU ARE IN AN EEA TWO, UH, MAY WORK IF MY OPERATING MARGIN DECLINES SLOWLY, BUT THAT IS NOT ALWAYS GOING TO BE THE CASE, AND CURTAILING LOAD WILL TAKE TIME.
SO, SOMETHING ELSE THAT, SO THERE ARE A FEW NUANCES TO KEEP IN MIND WHEN YOU START, WHEN WE START TALKING ABOUT CURTAILING LOAD, UH, FROM THE SYSTEM, THREE FACTORS IMPACT HOW QUICKLY A LOAD CAN BE CURTAILED.
AND, AND THOSE THREE FACTORS REALLY ARE TIME TO ACT.
SO HOW MUCH TIME DOES IT TAKE FROM T'S INSTRUCTION TO ENSURING THAT THE CUSTOMER CAN ACT AND RESPOND TO THE INSTRUCTION THAT IT WAS GIVEN FULLY RESPOND.
SO THEN THERE IS, THE NEXT ASPECT IS COORDINATION.
AS THE SIZE AND VOLUME OF LARGE LOADS GROW, UH, THERE MAY BE A VARIETY OF, UH, THERE MAY BE A, A DEEP TYPE OF COORDINATION THAT MAY NEED TO OCCUR.
SO WE MAY BE ISSUING INSTRUCTIONS WHERE SOME LOADS ARE BEING ASKED TO FULLY CURTAIL.
WE MAY BE ISSUING INSTRUCTIONS TO SOME LOADS, UH, THAT CAN CURTAIL IN SMALLER BLOCKS TO CURTAIL IN BLOCKS.
SO THERE IS COORDINATION AND THERE'S MORE COORDINATION ARE REQUIRED WHEN, UH, WHEN THE VOLUME OF LARGE LOADS INCREASES AND LARGER VOLUME OF CURTAILMENTS HAVE TO BE INSTRUCTED.
LASTLY, SOMETHING TO KEEP IN MIND IS IF WE CURTAIL TOO MUCH LOAD AT AT ONCE, THERE CAN BE A RISK TO FREQUENCY.
SO IN ORDER TO MAINTAIN RELIABILITY AS WELL, UH, CART IS GOING, THERE WILL BE A NEED TO INSTRUCT THESE LOADS TO CURTAIL AND TRANCHES.
UH, WE WILL NOT BE, LOOK, WE WILL TRY TO DO THIS IN A MANNER THAT WE CAN MAINTAIN RELIABILITY ON THE SYSTEM.
SO IF, UH, SO E SO, SO THE TAKEAWAY REALLY IS TODAY, EEA LEVELS ARE DECLARED WHEN OPERATING MARGIN HAS ALREADY FALLEN, WAITING FOR OPERATING MARGIN TO FOLLOW TO SUCH LOW LEVELS.
UH, WITH THAT SIMPLE MAPPING THAT I WAS JUST SHOWING YOU IN THE PREVIOUS SLIDE, MAY NOT LEAVE ENOUGH TIME FOR ERCOT TO FULLY UTILIZE THE SP SIX AUTHORIZED CURTAILMENT BEFORE FARM LOAD SHED IS NEEDED, UH, TO MAINTAIN FREQUENCY OR CONTINGENCY RESERVES.
SO, SO THIS, SO THIS IS A THOUGHT THAT REALLY, UH, UH, UH, IS A KEY, AT LEAST AS WE START TALKING DE DEEPER AND DEEPER
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ABOUT, UH, SB SIX.AND WHAT'S WRITTEN IN THE LAW IS CURRENTLY THE LAW CAN TEMPLATES ACTING WHEN RESERVES ARE LOW.
AND FIVE MC TWO C ONE AND TWO C TWO.
I'M GONNA PAUSE C IF SOMEONE'S ON THE PHONE CAN PLEASE MUTE.
IF YOU JUST SAID TWO C TWO, WE HEARD YOU SAY IT.
I, ALRIGHT, SO AGAIN, A SIMPLE MAPPING, UH, OR PUT OR SLIDING THESE WITHIN AN CURRENT EXISTING FRAMEWORK FOR EEA IS NOT VERY APPROPRIATE GIVEN THE VOLUME OF LARGE LOADS THAT WE ARE SEEING, UH, THAT MAY WILL POTENTIALLY IN INTERCONNECT INTO OUR SYSTEM AND THE, THE MECHANICS INVOLVED IN TAKING LOAD OFF THE SYSTEM.
SO, SO, SO I'LL PAUSE EXACTLY AT THIS LABEL AT THIS PLACE.
AND I REMEMBER I WAS MISSING TO TALK ABOUT SOMETHING HERE.
I'VE BEEN USING THE WORD OPERATING MARGIN AND I INTEND TO USE THAT WORD THROUGHOUT THIS DECK.
AND I'M, I'M, I, UH, AND THAT MARGIN IN MY MIND IS THE AMOUNT OF HEADROOM ON THE SYSTEM.
IT DOESN'T REPRESENT ANY PARTICULAR METRIC YOU'VE HEARD US TALK ABOUT, LIKE I MENTIONED PRC, BUT I WANT, I'M USING IT AS A STAND, A STAND IN TERM, UH, WHEN I REF, UH, WHEN I REFER TO MARGIN ON THE SYSTEM.
SO I'LL PAUSE WITH THIS AND I WILL SEE WHAT SORT OF QUESTIONS OR THOUGHTS I'VE STIRRED SO FAR.
I'M GONNA SEE WHERE MY QUEUE IS.
I THINK, I THINK I SHOULD BE FIRST IN THE QUEUE.
UM, SO THESE EEA LEVELS, THEY MADE SENSE AT 80 GIGAWATT SYSTEM.
ARE THEY STILL THE SAME AT 150 GIGAWATTS SYSTEM? SO, AND I DON'T ALWAYS LIKE THE QUESTIONS THAT I ASK, JUST TO BE CLEAR,
AND, UM, YOU MENTIONED THE LOAD SIZE.
I ALSO MENTIONED FROM THE LENS OF VOLUME OF DEPENDENCE ON ENERGY DURATION LIMITED RESOURCES.
SO THERE IS DEFINITELY A, UH, A SEPARATE CONVERSATION TO BE HAD AROUND WHAT IS THAT, UH, LEVEL, IF YOU RECOLLECT, UH, IN 20 23, 20 24 TIMEFRAME, WE CAME BACK WITH UPDATED STUDIES THAT HELPED US SET OR HELP US RAISE THE LEVEL, UH, LEVEL THREE EEA.
AND THAT WAS BASED OFF OF WHAT SORT OF, UH, SYSTEM DO WE EXPECT TO BE OPERATING WHEN WE TYPICALLY, UH, START SEEING TIGHT MARGINS.
SO SOME OF THOSE STUDIES PROBABLY DO HAVE TO BE REVISITED.
AND, AND, BUT AGAIN, IT'S TO ME IN MY MIND, A SEPARATE CONVERSATION REGARDLESS OF WHERE WE LAND.
SOMETHING THAT IS PROBABLY GOING TO BE TRUE IS THAT BECAUSE WE ARE SUCH AN ENERGY, UH, DURATION LIMITED RESOURCE DEPENDENT SYSTEM, NOW WE, UH, OUR EEA MARGINS MAY RUN VERY, ONCE WE ARE IN THOSE LOW LEVELS OF OPERATING, UH, CONDITIONS, MARGINS WILL DECLINE QUITE FAST.
AND REGARDLESS OF WHERE WE ARE, THE VOLUME OF LOAD THAT WE POTENTIALLY ARE STARING AT TAKING OFF, WE WILL HAVE TO DO SO GRACEFULLY, CAREFULLY, MAKE SURE WE MAINTAIN RELIABILITY.
SO THIS TOPIC IS STILL RELEVANT IN THAT WORLD WITH A SLIGHTLY DIFFERENT EEA LEVEL IS PROBABLY MY LONG SHOT AT A QUESTION THAT YOU WERE TRYING TO GET TO.
SO MAYBE ME THINK ABOUT IT LIKE, THIS WHOLE DISCUSSION IS TIED TO EEA LEVELS, NOT THE TRIGGER THAT WOULD TAKE YOU INTO THAT EEA LEVEL AND THE TRIGGER THAT WOULD, YOU KNOW, WHAT THOSE TRIGGERS ARE AND HOW THEY MIGHT CHANGE.
WE DO NEED TO DISCUSS THAT, BUT JUST NOT THAT, YOU KNOW, WE'RE TRYING TO SEPARATE OUT WHERE WE'RE TALKING ABOUT THINGS IN A WAY THAT EVERYBODY CAN ABSORB THE VOLUME THAT'S ALREADY COMING THROUGH THIS PRESENTATION.
AND SO THAT'LL BE A DIFFERENT, UH, DISCUSSION.
SO YOU HAVE A HALF DOZEN QUESTIONS IN THE QUEUE HERE.
NITKA UH, CAMERON, YOU'RE NEXT.
WE'RE GETTING BACKGROUND NOISE.
CAMERON WITH THE DATA CENTER COALITION.
THANK YOU FOR CONVENING THE WORKSHOP.
OBVIOUSLY A BIG TOPIC COMING OUT OF SB SIX.
UM, AS WE WENT THROUGH WINTER STORM, FERN AND ERCOT DID A GREAT JOB, UM, MANAGING THE, THE STORM AND THE DEMANDS THAT IT, IT PROVIDED.
[00:25:01]
ONE THING I I THINK THAT'S IMPORTANT AND YOU HIGHLIGHTED IS, IS THE COORDINATION PIECE IS, IS ESSENTIAL.AND SO, UM, AS, AS WE WORK THROUGH THIS, I THINK THE MORE FORMAL OUR PROCESS WE CAN ESTABLISH IN TERMS OF CONTACTING, UH, THE LOADS THAT WOULD BE REQUIRED TO CURTAIL IS ESSENTIAL.
UM, UP UNTIL THIS POINT WE'VE BEEN IN RELATIVELY UNCHARTED WATERS, SO IT'S BEEN A LITTLE BIT MORE INFORMAL.
SO THE, THE MORE THAT WE CAN DEFINE WHAT THAT LOOKS LIKE, AND I KNOW Y'ALL ARE THINKING ABOUT THIS, UM, UH, AND, AND I ENJOYED WORKING WITH WHAT ENJOYED, RIGHT? I MEAN, I'M, IT WAS, IT WAS GOOD TO WORK WITH Y'ALL AND, AND PREPARE FOR THAT STORM.
AND SO, UM, WHATEVER WE CAN DO TO, TO FORMALIZE THAT PROCESS AND LINES OF COMMUNICATION WHEN, YOU KNOW, INTERNET COULD BE DOWN OR ELECTRICITY COULD BE DOWN, UM, IS, IS REALLY BENEFICIAL.
SO I DON'T REALLY HAVE A QUESTION, JUST A STATEMENT.
UM, AND UH, I APPRECIATE Y'ALL'S ATTENTION TO THIS.
UH, NEXT UP BRIAN SAMS HEY NATIKA.
UM, WHEN I LOOK AT THESE, THESE ARE VERY BRIGHT LINES, BUT I ACTUALLY THINK THE STANDARD IS LOOSER THAN WHAT YOU'RE SHOWING HERE WITH THESE LEVELS OF OPERATING MARGIN RESERVES.
IT'S, IT'S THE STANDARD, AT LEAST IN MY APPROVED NET METERING ARRANGEMENT IS AN ANTICIPATION MM-HMM
AND SO I JUST WOULD LOVE TO SEE, UH, YOU KNOW, SOME CLEAR LANGUAGE ON WHEN A PARTY COULD ANTICIPATE THAT THE OPERATOR IS GONNA HIT THE BUTTON.
AND SO THAT'S THE DISCUSSION I'M HOPING TO HEAR TODAY IN CONTEXT OF NET METERED CURTAIL LEVEL LOADS.
IF I CAN EXPAND YOUR SENTENCE.
SO WHAT I'M GONNA DO IS, LIKE I SAID, TODAY, I'M GONNA SPEND VERY LITTLE TIME ON THE SPECIFICS WHEN IT APPLIES DIRECTLY TO NET METERED, CURTAIL LEVEL LOADS.
'CAUSE I, UH, IN MY MIND WHEN I LOOK AT IT, THAT LANGUAGE, LIKE YOU SAID, IS BROADER, BUT THAT BROADER LANGUAGE FROM AN OPERATIONAL IMPLICATION PERSPECTIVE GIVES ME MORE FLEXIBILITY.
RIGHT? AND, AND I, I WANNA UNDERSTAND YOUR FLEXIBILITY ABSOLUTELY.
UH, AND I WANT TO COME TO THAT, RIGHT? I WON'T COME TO THAT TODAY.
I WILL COME TO THAT IN THE NEXT WORKSHOP BECAUSE I WANT TO SPEND SOME TIME ALSO EXPLAINING, LIKE DAN MENTIONED, WHAT IS THE TRIGGER? WHAT AM I LOOKING AT? HOW WILL I KNOW IN ANTICIPATION OF, AND WHEN WE START GETTING INTO THOSE DETAILS, I WANT TO MAKE SURE I WALK YOU ALONG AT LEAST WHAT WE ARE THINKING AND GET THERE.
SO TODAY I WILL REQUEST, I WILL GIVE YOU AN IDEA OF SOMETHING THAT IS IN THE BACK OF OUR MINDS, BUT I WON'T GET INTO THE TECHNICAL DETAILS.
BUT MY COMMITMENT IS I'M TAKING A NOTE THAT THIS IS WHAT I NEED TO COME BACK AND GIVE YOU A CLEAR PICTURE OF WHEN I COME BACK FOR WORKSHOP TWO.
UM, ONE OF THE, ONE OF THE QUESTIONS OR SUGGESTIONS I GUESS I MIGHT HAVE HERE IS THAT THERE NEED TO BE ALSO CLEAR GUIDELINES FOR LOADS, LIKE A HIERARCHY FOR LOADS THAT FALL INTO MULTIPLE OF THESE BUCKETS.
BECAUSE, FOR INSTANCE, WHAT DO YOU DO IF YOU HAVE A BACKUP, YOU KNOW, A, A LOAD WHICH HAS BACKUP GENERATION MM-HMM
BUT WHICH IS ALSO BE PROVIDING EITHER A FREQUENCY ANCILLARY OR, OR IS ON THE TBPS UNDER FREQUENCY PROGRAM.
SANDEEP, SHARMA, UH, SANDEEP SMA NEXTERA.
HEY, NIKA, UH, JUST A REALLY A CLARIFICATION QUESTION.
SO IF YOU'RE A LARGE LOAD AND YOU DON'T HAVE A BACKUP AND YOU ARE NOT NET METERED, WHERE DO YOU FALL? YOU FALL IN, I'LL GO BACK TO THIS SLIDE SAND.
YOU ARE BASICALLY ON YOUR EX, SOMEWHERE WITHIN THE PURE LANGUAGE, THERE IS A REQUIREMENT THAT THOSE BACKUPS BE, UH, THEY WILL, THERE'LL BE BREAKERS TO ISOLATE THOSE, THOSE LOAD LARGE LOADS, WHICH ARE NOT NET METER OR BACKUP SUPPORTED.
SO THAT WOULD BE A REQUIREMENT THAT APPLIES TO YOU ALL.
AND, UH, TO THAT SORT OF A LARGE LOAD.
AND IT WOULD FALL UNDER THIS FIRM LOAD SHED BUCKET RIGHT HERE.
SO YOUR EX, THAT THAT PARTICULAR LARGE LOAD'S EXPOSURE TO CURTAILMENT WOULD BE UNDER FARM LOAD SHED THROUGH THE UTILITY, THROUGH THE UTIL.
NOW IS THAT BEFORE THE RESIDENTIAL FIRM LOAD, OR AT THE SAME TIME I'M LOOKING AT NATHAN SANDEEP, THE PUR DOES NOT SPEAK TO THE ORDER OF OPERATIONS THERE.
UM, AND SO I THINK THAT'S AN ISSUE TO BE DETERMINED.
[00:30:02]
ALL RIGHT, NEXT QUESTION.MARTHA HENSON WITH ENCO, UH, TIKA.
IN THINKING ABOUT THE CHALLENGES THAT YOU IDENTIFIED ON SLIDE 10, YES.
EARLIER, AND, AND GIVEN THAT WE'RE SEEING A, A VARIETY OF NEEDS WHERE ERCOT NEEDS TO HAVE OPERATIONAL CONTROL OVER LARGE LOADS, SOME OF WHICH ARE AN SB SIX, BUT OTHERS ARE ACTUALLY, UH, THINGS THAT STAKEHOLDERS HAVE IDENTIFIED, LIKE THE VECL PROGRAM, OTHERS THAT ERCOT HAS IDENTIFIED, LIKE THE LARGE LOAD IROL CURTAILMENT PROGRAM.
UH, THE QUESTION IS, WHAT ARE THE PROSPECTS OR OBSTACLES TO REQUIRING LARGE LOADS TO BE IN SC TO HELP ERCOT FACILITATE THIS OPERATIONAL CONTROL NEED? SO, UH, SO I'LL ANSWER IT THIS WAY.
I THINK, UH, I I WILL BE, UH, COULD, HAVING LARGE LOADS IN SC CERTAINLY IS A GOOD WAY FOR ERCOT TO, UH, OR FOR SC TO MANAGE LARGE LOADS AND SEND, SEND INSTRUCTIONS.
THEY COME WITH THEIR OWN, UH, AT LEAST AS FAR AS BEING A CLR GOES.
THERE ARE, THERE IS A, UH, THERE IS A REGISTRATION PROCESS OR THERE ARE SET OF REQUIREMENTS THAT THESE LARGE LOADS WOULD NEED TO BE ABLE TO DO TO GET THERE.
UH, SO AS, UH, SO, SO IF THE HURDLES CAN BE PASSED, I KNOW WE'VE MADE IMPROVEMENTS, UH, LAST YEAR AS WELL.
WE WERE WORKING ON REQUIREMENTS AROUND CLARIFYING WHEN PFR LANGUAGE AS AN EXAMPLE APPLIES, UH, AND HOW NOT HAVING PFR CAPABILITY, UH, CAN STILL, UH, HELP QUALIFY, HELP GET A CONTROLLABLE LOAD RESOURCE REGISTRATION POSSIBLE.
IF YOU CAN FOLLOW SKYPE DISPATCH.
SO THERE ARE NUANCES INVOLVED, UH, WITHIN THE REQUIREMENTS THAT THESE LARGE LOADS WOULD NEED TO MEET TO BE ABLE TO, UH, QUALIFY TO BE A CLR TO THE EXTENT THAT THEY CANNOT.
LANGUAGE LIKE THAT IS WRITTEN IN SP SIX WOULD BE OTHER WAYS OF MANAGING THE RELIABILITY RISK.
UH, SO AT LEAST WHEN, WHEN YOU HEAR ME TALK ABOUT THE TOPIC TODAY, I'M TALKING ABOUT IT FROM THE PERSPECTIVE OF LARGE LOADS WHO, WHO ARE EXPOSED TO CURTAILMENT UNDER SP SIX, UM, AND CAN AND TO THE EX, UH, AND TO THE EXTENT CANNOT BE CLRS BECAUSE IF THEY ARE CLRS, THERE'S PROBABLY WAYS TO ACT ON THEM.
I DON'T WANT TO GET INTO THE, THOSE LEVELS OF, UH, UH, UH, THE WORD IS DETAILS OR TECHNICALITIES TODAY WHAT I WANT TO SPEND AT LEAST SOME OF MY TIME TODAY TALKING JUST ABOUT THE LAW THAT IS WRITTEN, WHAT ARE ITS IMPLICATIONS, AND THEN WE CAN TALK ABOUT WHAT CAN BE DONE, UH, IN TERMS OF MEETING THE LAW AND STILL AND MAINTAINING RELIABILITY, WHICH IS THE OVERALL OBJECTIVE.
THANKS, UH, CHRIS HENDRICKS NEXT.
THANKS, UH, NIKA, GOOD MORNING.
UH, CAMERON KIND OF ALLUDED TO IT, BUT ON THE, UM, ON THE SCOPE OF THE ITEMS MM-HMM
I DIDN'T SEE ANY MENTION OF THE DOE ORDERS THAT CAME ABOUT IN JANUARY THAT KINDA GO ABOVE AND BEYOND SENATE BILL SIX.
IS THAT GONNA BE OUTTA SCOPE AND KIND OF COVERED IN A FUTURE, FUTURE DEVELOPMENTS, AT LEAST FOR THIS ONE? YES.
I THINK YOU ARE REFERRING TO THE, THE FERC RELATED, THE 2 0 2 DOE RELATED STUFF.
SORRY, THE 2 0 2 CI, THIS PARTICULAR, UH, TOPIC RIGHT NOW IS AT LEAST NOT IN THE SCOPE OF WHERE WE ARE TODAY, BUT I'M HAPPY IF YOU HAVE QUESTIONS SPECIFICALLY ON IT OR IDEAS SPECIFICALLY FOR IT.
UH, 'CAUSE UH, LIKE I SAID, MY, MY, I WILL USE THE WORD SB SIX TWO MANY TIMES TODAY, BUT OUR KEY FOCUS IS SB SIX.
AND I DO UNDERSTAND, UH, THE, THE, UH, THAT THAT PARTICULAR TOOL THAT TWO TWO C CREATED IS SOMETHING WE NEED TO, I, WE, WE PROB WE WE NEED TO HAVE CLEAR, UH, PROCEDURES AROUND.
SO HEARING THOUGHTS OR HEARING WHAT YOUR NEEDS ARE ON IT WILL BE VERY HELPFUL.
AND I THINK WE CAN BUILD UPON WHAT WE DISCUSSED HERE ON SIMPLE BILL SIX TO KIND OF DEVELOP, DEVELOP THOSE PROTOCOLS AS WELL.
I SAY THAT YOU SAID THAT'S OKAY.
MY QUESTION WAS THE SAME AS SANDEEP.
SO TO CONFIRM, A LARGE LOAD THAT IS NOT NET METERED AND DOES NOT HAVE 50% BACKUP IS NOT CURTAILED UNTIL FIRM LOAD SHED IKA IS NODDING MY, UH,
UH, WELL, AT THIS POINT, THE WAY SB SIX IS WRITTEN, IT IS NOT EXPOSED TO CURTAILMENT, UH, PRIOR TO FARM BLOODSHED.
ALL RIGHT, LEE, DOES THAT ANSWER YOUR QUESTION? ALRIGHT, WE'LL MOVE ON.
UM, NED, DID YOU WANNA MAKE A COMMENT? I WAS
[00:35:01]
JUST DROPPING SOME INFORMATION IN THE CHAT TO YEP.UM, I WILL ADD, THOUGH, JUST WHILE, WHILE I HAVE THE MIC OPEN, THIS MAY BE JUMPING IN FRONT OF ERIC, UH, FOR THE NET METERING ARRANGEMENTS THERE, YOU KNOW, THERE MAY BE COMMITMENTS THAT ARE MADE THAT, YOU KNOW, VARY FROM THE CONDITIONS THAT ARE IMPOSED.
AND SO YOU MAY WANT TO HAVE SOME, UH, AT LEAST RECOGNITION OF THAT IN THE LANGUAGE AND, AND ADDED FLEXIBILITY AROUND IT.
ERIC GOFF, I HEARD YOU WHEN YOU SAID, WE WON'T BE TALKING ABOUT THIS, SO I DON'T EXPECT A RESPONSE.
UM, BUT ON THE POINT OF NET METERED LOAD, UM, SHED, UM, I REALLY THINK THAT WE HAVE A LITTLE BIT OF A PANDORA BOX PROBLEM, PANDORA'S BOX PROBLEM, BECAUSE THE, UM, CONDITIONS IMPOSED IN SOME OF THE CASES SO FAR ARE SO BROAD.
AND SO, YES, YOU HAVE THAT FLEXIBILITY AND THAT'S GOOD, BUT WE WILL NEED TO HAVE LIKE CLEAR PROCEDURES SO EVERYONE IS TREATED IN A, IN A SIMILAR WAY.
SO, AND YOU KNOW, WE ALSO DON'T WANT TO CREATE AN INCENTIVE FOR PEOPLE TO NOT HAVE GENERATION.
UM, SO THAT'S JUST AN IMPORTANT COMPONENT.
MAYBE I'LL, I'LL TRY TO BE A LITTLE MORE CLEAR IN MY RESPONSE ONCE AGAIN.
SO, UH, UH, OUR, WE ARE, WE UNDERSTAND THAT WE NEED THE CONDITIONS AS WRITTEN ABROAD, AND WE NEED TO PROVIDE MORE DETAILS.
PURPOSE OF STARTING THESE WORKSHOPS IS TO START SHARING EXACTLY WHAT WE ARE THINKING SO WE CAN REACH TO A, UH, REACH TO A POINT WHERE THOSE CLEAR GUIDE RULES CAN BE DRAFTED WITHIN THE PROTOCOLS AND BROUGHT FORTH.
SO IT'S A WAY EVERYBODY IS AWARE OF WHAT THEY ARE.
SO REALLY THAT IS THE ULTIMATE GOAL.
UH, I, I REALLY LIKE THAT ANSWER.
UM, TO THE EXTENT THAT A COMMISSION ORDER GIVES YOU BROAD AUTHORITY, BUT THEN YOU CLARIFY HOW YOU USE THE AUTHORITY OF THE PROTOCOLS.
THERE IS A CONTRAST, AND I REALLY, UH, UH, THE PIECE THAT I HOPE BY THE END OF TODAY GETS CLEARED, AT LEAST TO THOSE WHO'VE BEEN FOLLOWING THE NET METERING PROCESS.
THERE IS A CONTRAST IN WHEN AN ACTION, WHEN AN INSTRUCTION CAN BE GIVEN AND HOW BETWEEN THE TWO.
AND I WANT TO TRY AND GET THAT POINT ACROSS TODAY AT LEAST.
AND THEN WE CAN BUILD FROM THERE AS WE COME, UH, WITH THE FOLLOWING, UH, WORKSHOPS.
MAYBE, YOU KNOW, THINK IF I CAN, MATT SAID THIS AT THE BEGINNING, AT THE BEGINNING, BUT NOW THAT WE'VE HAD SOME DISCUSSION, MAYBE IT'S GOOD TO KIND OF REPEAT IT, IS, I MEAN, WE HAD ALREADY STARTED DOWN THE PATH OF WRITING PROTOCOL LANGUAGE JUST TO KIND OF GET, HOW IS THIS GONNA WORK? AND THEN WE REALIZED, OKAY, THERE'S SOME POLICY ISSUES IN HERE THAT NEED TO BE DECIDED THAT IT'S NOT CLEAR WHICH WAY IT NEEDS TO GO.
AND SO LET'S DO THESE WORKSHOPS, LET'S TALK ABOUT THOSE THINGS, AND THEN WE CAN INCORPORATE THAT.
BUT ULTIMATELY THERE'S GONNA BE PROTOCOL LANGUAGE THAT SAYS, THIS IS HOW WE'RE GONNA DO THIS.
AND SO I, I REALLY APPRECIATE THAT, AND AS SOMEONE THAT'S COMPLAINED ABOUT NPRS BEING PUBLISHED BEFORE WE HAVE THESE DISCUSSIONS, I'M NOT ASKING YOU TO DO THAT.
I APPRECIATE THE DIRECTION THAT WE'RE GOING ON.
AND THEN LET ME DO THIS ONE MORE QUESTION JUST CAME IN, UH, AND THEN WE'RE GONNA HOLD THE QUEUE AND LET, UH, NITKA MOVE ON.
SO ARUNA TYPED INTO THE CHAT, IT SAYS, UNDER NET METERING AND BSCL, ARE WE REQUIRING THAT BEHIND THE METER ONSITE GENERATION BE INJECTED INTO THE GRID AFTER CURTAILING THE LARGE LOAD? SO IN CASE OF NET METERING, UH, THE, UH, THAT IS CO-LOCATED WITH AN EXISTING GENERATION RESOURCE, THE CONDITIONS, UH, THE WAY, UH, THEY ARE WRITTEN IS THE GENERATION RESOURCES CAPABILITY.
THE CO-LOCATED RESOURCES CAPABILITY MUST BE MADE AVAILABLE TO A COT.
SO THAT'S, UH, UH, THAT'S ONE PLACE WHERE THE, THE LAW OR THE RULE CONDITIONS THAT HAVE BEEN PASSED DIRECTLY TALK ABOUT WHAT IS CO-LOCATED AND REGISTERED WITH
REALLY, THE LANGUAGE IN PURA FOCUSES JUST ON THE LARGE LOAD.
WHAT ELSE IS AT THE FACILITY, HOW IT OPERATES IS GOVERNED BY THE RULES FOR THAT PARTICULAR, UH, I, FOR THAT PARTICULAR RESOURCE AND HOW IT'S RE REGISTERED WITH
NATHAN HAS HIS HAND ON THE MIC, SO I'M GONNA INVITE HIM TO SEE IF HE WANTS TO CHAT.
NIKA, I WAS GONNA SAY, I MEAN, I THINK PIRA IS, IS IS PRETTY CLEAR ON THE BACKUP SUPPORTED CURABLE LOADS THAT WE'RE REALLY TALKING ABOUT GENUINE OFF GRID BACKUP GENERATION IN THE CONTEXT.
YOU KNOW, THERE COULD BE SOME CO-LOCATED GENERATION IN THAT CASE, BUT I THINK THE, THE TRIGGER FOR THE INVOCATION OF THAT LANGUAGE IS THAT YOU HAVE 50% OR MORE BACKUP, YOU KNOW, GENERATION THAT'S OFF GRID, NOT REGISTERED WITH ACOT, NOT CAPABLE
[00:40:01]
OF INJECTING INTO THE GRID, NOT NOT REGISTERED IN ANY WAY.UM, AND THAT'S REALLY THE, THAT'S KIND OF THE TRIGGER FOR THAT SPECIFIC CATEGORY OF CURTAILMENT.
AND SO, UM, AS WE READ THE LANGUAGE IN THE STATUTE, IT'S REALLY KIND OF UP TO YOU HOW YOU DECIDE TO MANAGE YOUR LOAD ONCE IT GETS OFF THE GRID.
UM, WE ARE NOT GONNA MANAGE THAT GENERATION.
UM, WHAT HAPPENS OFF THE GRID IS YOUR BUSINESS NOT, OR CUTS.
AND SO, UM, I JUST WANNA MAKE THAT THAT CLARIFICATION.
NET METERING IS A, A WHOLE DIFFERENT ANIMAL.
THE COMMISSION HAS VERY SPECIFIC CONDITIONS THAT IT HAS IMPOSED THUS FAR IN THOSE THREE PROCEEDINGS.
AND, UM, YOU KNOW, AND THAT'S A, A, A VERY DIFFERENT PARADIGM COMPARED TO THE BACKUP SUPPORT OF CURABLE LOAD, WHICH IS REALLY FOCUSED ON THE LOAD ACTION AS NIKA SAID.
SORRY, NIKA, I ACCIDENTALLY DROPPED BILL BARNES OUTTA THE QUEUE.
UH, NATHAN, ON THE PRIORITY OF LOAD SHED IN E EEA THREE, WE TALKED ABOUT, UH, LARGE LOADS SUBJECT TO 3 9 1 70 A, WHICH ARE TRANSMISSION CONNECTED, BY THE WAY, IT DOESN'T HAVE TO BE A LARGE LOAD.
YOU CAN BE 10 MEGAWATTS CONNECTED TO THE TRANSMISSION SYSTEM AFTER DECEMBER 31ST, 2025.
SHE THE PRIORITY BETWEEN THE TRANSMISSION CLASS AND THE DISTRIBUTION CLASS OF CUSTOMERS UNDER FIRM IN EEA THREE.
DO YOU KNOW WHEN OR WHERE WE MAY DISCUSS THAT, ADAM? 'CAUSE IT HAS SOME PRETTY IMPORTANT PUBLIC, UM, IMPACTS THAT WE, I THINK NEED TO TALK THROUGH.
I MEAN, AT THIS POINT, THE WAY IT WOULD WORK IS THAT, THAT THOSE LOADS THAT REMAIN AFTER AND MYTHICAL GET TO THIS LATER, BUT THE LOADS THAT REMAIN AFTER THEY, THEY'RE NOT IN ONE OF THESE OTHER CATEGORIES.
SHE CATEGORIES WOULD BE IN THE LOAD SHE TABLES ALLOCATED OUT TO EACH OF THE TSPS OR THE TOS.
AND THEY, UH, SO THAT WOULD BE IN THEIR SHARE.
AND THEN WHEN WE SAY SHED THAT FIRM LOAD EACH TO WOULD DECIDE WHAT, HOW TO DO THAT, HOW TO DO THAT AT THIS POINT.
AND SO, YOU KNOW, IF WE WANT TO CHANGE THAT SOMEHOW, THEN WE, WE, THE STAKEHOLDER COMMUNITY, UH, CAN, CAN WORK ON THAT.
BUT AT THIS POINT, THAT'S HOW IT DO, IT'D BE EACH TDSB DECIDING THAT.
SO THIS, THIS NECESSARILY WON'T BE A SUBJECT AT A FUTURE WORKSHOP? NOT, NOT ON OUR LIST AT THIS POINT.
I MEAN, I DON'T THINK WE WOULD BE OPPOSED TO THAT BEING RAISED.
YOU BY STAKEHOLDERS IN THE PROCESS OR, YOU KNOW, AT THE PUC.
BUT, UM, I'M NOT SURE THAT'S SOMETHING THAT, THAT ARCOT ITSELF AT THIS POINT IS ENVISIONING, UH, PUSHING FROM OUR END.
ALRIGHT, SO I, I'VE SAID IT A FEW TIMES, UM, I, AGAIN, ON THIS PARTICULAR SECTION AND HOLD THE QUESTIONS TILL WE REACH THE END OF THIS SLIDE.
'CAUSE I, THE, THE SLIDES HAVE BEEN SET IN A SEQUENTIAL ORDER AND I WANNA KIND OF KIND OF WALK YOU THROUGH THOSE SLIDES BEFORE WE, BEFORE WE GET, UH, AND START ASKING DETAILED QUESTIONS, START ANSWERING DETAILED QUESTIONS.
ALRIGHT, SO THIS, UH, AND I MEAN, UH, THIS SECTION IS REALLY DEDICATED TO BACKUP SUPPORTED CURTAIL LEVEL LOADS.
AS I MENTIONED, AGAIN AND AGAIN, THE LANGUAGE FOR HOW THESE LOADS MUST BE CURTAILED IS WRITTEN WITHIN THE LAW THAT, UH, THAT WAS PASSED UNDER SP SIX.
AND I'VE ACTUALLY, THE BOX, THE GRAY BOX HERE REPLICATES THE LANGUAGE OR THAT, UH, THAT, UH, ONE SENTENCE THAT PROBABLY CAPTURES IT ALL.
IT IMPOSES TWO KEY CONDITIONS ON OUR CUT OR, UH, FOR CURTAILMENT, WE MAY INSTRUCT CURTAILMENT ONLY AFTER ALL MARKET SERVICES ARE DEPLOYED EXCEPT FOR FREQUENCY AND INSTRUCT THE UTILITY, WHICH WILL THEN, WHICH IS THEN EXPECTED TO COORDINATE WITH THE CUSTOMER.
NOW, OUR UNDERSTANDING OF, UH, THE, YOU KNOW, SB SIX AND THE ACTIONS THAT WERE, UH, UH, AND THE WORK THAT WAS DONE AS A PART OF IT WAS, UH, WAS TO ENSURE THAT LARGE LOAD ADDITIONS DO NOT INCREASE FIRM LOAD SHARED RISK FOR RESIDENTIAL AND OTHER CUSTOMERS.
AND, AND WHEN WE START THINKING ABOUT THIS PARTICULAR LANGUAGE AND CONTEXT OF THAT GOAL, IT, UH, THERE ARE CERTAIN THINGS THAT ARE WORTH THINKING THROUGH.
SO THIS PARTICULAR, UH, SECTION OF THE, UH, THE WORKSHOP IS REALLY, UH, TO, TO TALK THROUGH WHAT ARE THE OPERATIONAL IMPLICATIONS OF THESE TWO KEY CONDITIONS THAT, UH, THAT ARE WITH TEMPLATED WITHIN THE LANGUAGE OF PURA.
I'LL FIRST START BY TALKING A LITTLE BIT ABOUT THE LIMITATIONS OF ROUTING
[00:45:01]
INSTRUCTIONS THROUGH THE UTILITY.AS I MENTIONED, THAT'S, UH, THE PATH THAT, UH, SP SIX TEMPLATES FOR INSTRUCTING CURTAILMENTS TO BE SCLS.
NOW, OF COURSE, AS YOU CAN, UH, IT'S AN ADDITIONAL STEP.
IT'S AN ADDITIONAL COORDINATION STEP THAT, UH, UH, IS TEMPLATED, WHICH SAYS
NOW, THAT ADDITIONAL STEP CAN LENGTH CURTAILMENT RESPONSE TIME, OR SHORTEN THE AMOUNT OF TIME THE LARGE LOAD HAS TO ACT.
AGAIN, THIS KEY, UH, UH, SET OF WORDS, CURTAILMENT RESPONSE TIME, I'LL USE THIS OFTEN THROUGHOUT THIS PORTION OF THE DECK AND SLIGHTLY LATER.
AND WHAT I MEAN BY IT IS, UH, THE TIME IT TAKES FROM A CUT TO INSTRUCT AND FOR THE LOAD TO FULLY RESPOND TO THE INSTRUCTION IT WAS GIVEN IS THE CURTAILMENT RESPONSE TIME.
UH, UH, NOW, WHEN YOU ADD AN ADDITIONAL ENTITY WITHIN IT, THERE'S A POTENTIAL THAT THAT RESPONSE TIME CAN INCREASE BECAUSE THERE'S COORDINATION INVOLVED, OR IT CAN REDUCE THE AMOUNT OF TIME THE LOAD HAS TO ACT.
NOW, SOMETHING ELSE, UH, TO THINK THROUGH IS AS THE VOLUME OF LARGE LOADS GROWS, AND AS THE VOLUME OF B SCLS GROW, THIS COORDINATION CAN BECOME MORE COMPLICATED.
THERE'LL BE MORE SITES, MORE SITES.
WITH LARGER CONJUNCTIONS, WE ARE ALREADY SEEING THE QUEUE HAVING A GIGAWATT PLUS LARGE LOADS, UH, LOOKING TO INTERCONNECT INTO THE SYSTEM.
NOW, SOME OF THESE LARGE LOADS MAY HAVE CAPABILITY TO CURTAIL IN SMALLER BLOCKS, SOME MAY NOT.
SO THE INSTRUCTIONS THAT ARE CAUGHT, UH, MAY NEED TO ISSUE ARE THE ACTIONS THAT MAY NEED TO TAKE MAYBE A FULL CURTAILMENT OR A BLOCK CURTAILMENT.
AND ALL OF THOSE ACTIONS WOULD EVENTUALLY NEED TO BE COORDINATED WITH THE CUSTOMER.
THIS, UH, UTILITY ROUTING, UH, UH, UH, IDEA WAS PROBABLY MANAGEABLE.
BUT AS THE VOLUME GROWS, THE COMPLEXITY OF THE INSTRUCTIONS GROW, THERE IS, UH, IT IS, UH, UH, IT IS, THERE IS AN INCREASED RISK OF MISCOMMUNICATION.
THERE IS INCREASED RISK OF DELAYS IN ACTIONS.
SO THOSE ARE THINGS THAT AT LEAST COME TO OUR MINDS WHEN WE THINK ABOUT THIS LIMITATION OF, UH, ROUTING THROUGH THE UTILITY.
NOW, WE WERE ALSO, AT LEAST WHEN WE WERE, UH, THINKING THROUGH THIS, WE WERE ALSO TALKING ABOUT WHAT HAPPENS IF WE NOTIFY BOTH THE, UH, THE UTILITY AND THE CUSTOMER.
I MEAN, THAT'S ALSO NOT FREE FROM ERRORS.
UH, IT IT, IT CREATES ITS OWN, UH, CHANNEL OF COMMUNICATION.
THERE ARE NOW TWO CHANNELS OF COMMUNICATION.
IT'S POSSIBLE BOTH OF THEM DON'T AGREE ON THE INSTRUCTION.
IT'S POSSIBLE THAT THE CUSTOMER IS STILL WAITING FOR ITS INSTRUCTION FROM THE UTILITY.
ALL OF THAT ADDS TO THE SAME RISK.
IT'S EITHER THE INSTRUCTIONS GET DELAYED OR MISCOMMUNICATED.
SO AT LEAST, UH, IN OUR MINDS, THIS, THE, UH, UH, WHEN WE THINK THROUGH THE PURE LANGUAGE, WE SEE SOME LIMITATIONS, UH, IN ROUTING INSTRUCTIONS THROUGH THE UTILITY.
AS I MENTIONED, CURTAILMENT RESPONSE TIME, UH, IS THE ONE THAT EITHER INCREASES OR DOESN'T LEAVE ENOUGH TIME FOR LOAD TO ACT.
NOW, IF THE CURTAILMENT RESPONSE TIME INCREASES, SOMETHING ELSE TO KEEP IN MIND IS THE LONGER IT TAKES FOR A LOAD TO CURTAIL, THE EARLIER ERCOT MAY HAVE TO START ISSUING INSTRUCTIONS TO CURTAIL.
SO WE START AT THE PROCESS OF ASKING LORD TO SHED EARLIER.
SO AT LEAST, UH, UH, FOR US, UH, THE CURTAILMENT RESPONSE TIME THAT GETS ESTABLISHED FOR ACTIONS NEEDS TO BE THE SHORTEST PRACTICABLE PERIOD FROM WHEN OUR COURT INSTRUCTS TO WHEN THE ACTION CAN BE DELIVERED, UH, AND THAT IT, UH, UH, AND THAT EFFECTIVELY, UH, ENSURES THAT WE, WE TAKE ACTIONS AT THE LAST TIME WHEN AN ACTION CAN BE TAKEN AND, UH, UH, RELIABLY IMPLEMENTED.
NOW, WHAT I'M GONNA DO IS FROM THIS POINT ON, I'M GONNA DEVIATE, AND I'M GONNA USE AN ILLUSTRATIVE EXAMPLE TO TRY AND, UH, SHARE, TO SHARE HOW WE SEE THE, UH, IMPACT OF THIS INSTRUCTION, TIMING OR WHEN TO ISSUE AN INSTRUCTION THAT IS TEMPLATED WITHIN THE PURE LANGUAGE, UH, UH, ON, IN, IN, DURING AN EA PROCESS.
AND I'LL, I, UH, I'LL, I'LL ASSESS IT TWO WAYS.
IN A WORLD THAT
[00:50:01]
MUCH LEVEL OF CONSUMPTIONS, UH, UH, ARE HAPPENING IN REAL TIME AND IN A WORLD WHERE THERE IS VISIBILITY.SO THERE ARE TWO SCENARIOS THAT I WILL, UH, LOOK, UH, TO USE, UH, IN THE NEXT THREE SLIDES TO, UH, UH, TO PROVIDE SOME INSIGHTS, UH, INTO HOW THE, THIS, UH, IDEA OF CURTAILING ONLY WHEN RESERVES ARE LOW MAY PLAY OUT IN OPERATIONS.
AND ALL OF THE CHARTS THAT YOU WILL SEE, THEY HAVE A, THEY, THEY, THEY HAVE A VERTICAL STANDARD CHART ON TOP, A CHART ON BOTTOM.
THE CHART ON TOP IS LOOKING TO SHOW OPERATING MARGIN AS IT EVOLVES IN REAL TIME CHART ON THE BOTTOM SHOWS LOAD CURTAILMENTS.
AND THERE ARE THREE CATEGORIES, OR THREE OR FOUR CATEGORIES THAT YOU WILL SEE WHEN THEY COME.
AND THE SCENARIO THAT WE'VE PICKED TO DEMONSTRATE THE IMPACT OF TIMING AND VISIBILITY, IT'S THE SAME OPERATING CONDITION.
SO THE NET LOAD IS SAME IN, UH, BOTH THE SYSTEMS. UH, THE VOLUME OF NET MEET AT CURTAIL LOAD BACKUP, SUPPORTED CURTAIL LOAD AVAILABLE ARE THE SAME EMERGENCY TOOLS, EEC, ERS, AND CLRS, THEIR VOLUME WHEN THEY TRIGGER ARE ALL AS CONTEMPLATED IN THE PROTOCOLS.
TODAY, WE HAVE LOCKED IN ONE THING, AND THAT ONE THING IS THIS CURTAILMENT RESPONSE TIME.
WE'VE LOCKED IN A 30 MINUTE CURTAILMENT RESPONSE TIME FOR ALL THE NET METER MEGAWATTS THAT ARE IN THIS EXAMPLE, AND ALL, EVEN ALL THE BACKUP SUPPORTED CURTAIL LOAD.
SO WE'VE TAKEN THAT PARTICULAR VARIABLE OUT AS FAR AS THIS DEMONSTRATION GOES.
AND FOR NECK METERED CURTAIL LOADS, WE START IN THE, IN THIS, IN THESE ILLUSTRATIVE EXAMPLES, CURTAILING THEM WHEN OUR NEAR TERM FORECASTS INDICATE THAT OPERATING MARGIN WILL FALL BELOW 2,500 MEGAWATTS.
SO, SO THESE ARE THE ONLY LOADS THAT ARE ACTING BASED OFF OF A FORECASTED CONDITIONS.
UM, B SCLS, LET'S TALK ABOUT B SCLS SEPARATELY.
SO WHAT DIFFERS FOR THE BACKUP SUPPORTED LOADS? LIKE I SAID, THERE ARE TWO SCENARIOS.
THERE IS A SCENARIO WHERE WE CURTAIL THEM BASED OFF OF REAL TIME THRESHOLDS.
SO WHATEVER IS THE OPERATING MARGIN AS WE SEE, UH, IN REAL TIME WITHOUT ANY VISIBILITY OF THE LOADS.
AND THE SECOND SCENARIO IS WE CURTAIL THEM USING A NEAR TERM FORECAST INFORMED OPERATING MARGIN.
SO SIMILAR TO THE, UM, UH, FORECAST WE WOULD USE FOR NET METER LOADS, THE ADDITIONAL THING WE PUT IN THAT SECOND SCENARIO IS WE ADD VISIBILITY.
SO WHAT DOES VISIBILITY REALLY DO? IN THE SCENARIO WHERE WE ARE USING REAL TIME THRESHOLDS AND NO VISIBILITY? WE CANNOT SEE, UH, WE DON'T KNOW WHAT THE LOADS, UH, ARE DOING IN REAL TIME.
SO WE DON'T KNOW WHAT THEIR CUR, UH, HOW MUCH RESPONSE THEY CAN DELIVER.
WE DON'T KNOW WHAT THEIR CURTAILMENT CAPABILITY IS.
CAN THEY CURTAIL IN BLOCKS? WILL THEY CURTAIL, UH, AS A FULL CHUNK? UH, WE, WE DO NOT HAVE THAT ABILITY TO UNDERSTAND IN THE WITHOUT VISIBILITY SCENARIO.
SO OUR INSTRUCTIONS THAT WE ISSUE IN THAT SCENARIO ARE BASED ON WHAT THE SYSTEM NEEDS.
WE WAIT TO SEE WHAT IS DELIVERED, AND ONCE THE, THE INSTRUCTIONS, ONCE THE RESPONSE HAS STABILIZED, WE GO OUT AND ISSUE ANOTHER INSTRUCTION BECAUSE HOW MUCH RESPONSE WE GET WILL BE UNCERTAIN IN SUCH A, IN THAT SITUATION.
IN ORDER TO AVOID CREATING A FREQUENCY, UH, RISK, WE SPACE OUT SUBSEQUENT INSTRUCTION.
SO WE TAKE LONGER TIME BEFORE A SECOND INSTRUCTION IS ISSUED TO MAKE SURE THAT WE DON'T ACCIDENT.
UH, WE DON'T CREATE A SITUATION WHERE LOTS OF LOAD CAN TRIP AT THE SAME TIME IN THE NEAR TERM FORECAST INFORMED CASE WHERE WE HAVE VISIBILITY, WE KNOW EXACTLY WHERE THE LOAD IS, WE KNOW WHAT THEIR CURTAILMENT CAPABILITIES, WE KNOW WHO CAN CURTAIL AND BLOCKS, WE KNOW WHO CAN CURTAIL FULLY.
WE ARE ABLE TO TAILOR OUR INSTRUCTIONS BASED OFF OF THE LARGE LOADS AND THEIR CAPABILITY AND WHAT THEY ARE CONSUMING IN REAL TIME.
SO DOING SO GIVES US MORE CERTAINTY THAT WE KNOW WHAT WE WILL GET.
THE RESPONSE OF THE INSTRUCTION IS EFFECTIVELY BOUNDED.
SO WE HAVE, UH, WE ARE IN THOSE SITUATIONS BECAUSE WE KNOW CLEARLY WHAT WE'LL GET.
WE ARE INSTRUCTING BASED OFF OF NOT JUST WHAT THE SYSTEM NEEDS, BUT WHAT THE LARGE LOADS CAN PROVIDE OR DELIVER.
WE ARE ABLE TO ISSUE SUCCESSIVE INSTRUCTIONS CLOSER TOGETHER.
WE DON'T NEED TO SPACE THEM APART AS MUCH.
WE ARE ABLE TO MANAGE FREQUENCY RISK BECAUSE WE HAVE AWARENESS EFFECTIVELY IS THE IDEA HERE.
NOW, WHAT DOES THIS SETUP DO? I'LL START BY FIRST SHOWING YOU THE REAL TIME, UH, THRESHOLD WITHOUT VISIBILITY CASE.
AND LIKE I SAID, UH, UH, THIS IS THE, UH, THERE ARE TWO GRAPHICS IN THIS CHART.
THE TOP GRAPHIC IS TRACKING OPERATING MARGIN THAT WE SET UP IN THIS CASE, UM,
[00:55:01]
BASED OFF OF THE OPERATING CONDITIONS THAT WERE RESUMED, WE HIGHLIGHT THE THREE EEA THRESHOLDS, JUST SO, SO FOR YOUR AWARENESS.AND THE VERTICAL MARKERS TELL YOU WHEN THE OPERATING MARGIN IS DROPS BELOW THOSE THRESHOLDS.
THE BOTTOM GRAPHIC SHOWS YOU CURTAILMENT RESPONSE.
THE BLUE LINE IS CURTAILMENT RESPONSE FROM NET METER CURTAIL LOADS, SORRY, THE LIGHT BLUE LINE.
THE DARK BLUE LINE IS RESPONSE FROM BACKUP SUPPORTED CURTAIL LOAD.
SO IN THIS PARTICULAR SCENARIO, IF YOU RECOLLECT, I HAD SAID, WE WILL, UH, ISSUE INSTRUCTIONS TO CURTAIL NET METER LOSS BASED OFF OF FORECAST NEAR TERM FORECASTS OF, UH, OF THE SYSTEM AND HENCE, UH, UH, AN ESTIMATION OF OPERATING MARGIN.
SO WHENEVER THOSE NEAR TERM FORECAST INDICATE THAT OPERATING MARGIN MAY DROP BELOW 2100, WE START ISSUING INSTRUCTIONS AND, UH, EVENTUALLY EVEN BEFORE EEA ONE HITS.
SO THIS IS SOMEWHERE AROUND THE 220 MINUTE MARK.
WE, WE HAVE, UH, INSTRUCTED ALL OF THE NET METER LOADS, UH, TO CURTAIL THE, UH, AS THE, UH, AS THE CONDITIONS CONTINUE, UH, MARGINS FALL BELOW EEA ONE AT 235 MINUTES AND EVENTUALLY BELOW EEA TWO AT 255 MINUTES.
NOW, IF YOU RECOLLECT, I HAD SAID THE VPI IS WRITTEN FOR B SCLS.
UH, WE, WE, UH, TO MEET THE IDEA OF AFTER ALL MARKET SERVICES HAVE BEEN DEPLOYED AND ONLY FREQUENCY RESERVES LIVE IN EEA TWO IS PROBABLY THE MAPPING, UH, IS AN APPROPRIATE MARKER.
SO HERE, WHEN THE OPERATING MARGIN DROPS BELOW EEA TWO, UH, FIRST ROUND OF BSCL INSTRUCTIONS ARE SENT OUT.
AND REMEMBER WHAT BLUE LINE IS? IT'S RESPONSE, IT'S NOT WHEN THEY WERE, UH, IT'S NOT INSTRUCTION BUT RESPONSE.
SO FIRST ROUND OF INSTRUCTIONS GO OUT EXACTLY AROUND THE TIME WHEN E EEA TWO, UH, UH, LEVELS ARE REACHED.
YOU WILL NOTICE THIS GREEN DASH NINE, UH, THIS IS REPRESENTING RESPONSE FROM ERS AND NCL LRS.
SO ABOUT 10 MINUTES AFTER BEING IN AN EA TWO, THOSE RESPONSE START HITTING THE SYSTEM.
NOW, WHILE, UH, AND, AND NOW SINCE THE OPERATING MARGIN IS STILL DECLINING, WE ARE ABLE TO, WITH SOME SPACE, SEND OUT INSTRUCTIONS FOR B SCLS.
BUT IN THIS PARTICULAR SITUATION, MARGIN DROPS BELOW E EEA THREE, UH, SOMEWHERE IN THAT 280, UM, MINUTE RANGE, LITTLE BIT OF THE B SCL L INSTRUCTION THAT WE CAME AT, UH, INSTRUCTION THAT WERE GIVEN WHEN EA TWO WAS HIT.
YOU CAN SEE THEY, THEY ARE STARTING TO BUILD UP, BUT SINCE WE ARE ALREADY IN AN EEA THREE, WE WOULD START ALSO INSTRUCTING FIRM LOAD SHED TO COME OFF.
AND YOU'LL NOTICE THAT EARLY, UH, ONCE WE ARE IN EEA THREE FIRM LOAD SHED INSTRUCTIONS BUILD UP, UH, UH, AND, UH, UH, MORE, MORE SO, UH, THAN WHILE B SCLS ARE STILL GETTING INSTRUCTED AND THEIR RESPONSE IS SLOWLY BUILDING UP.
SO REALLY THIS, UH, THE POINT THAT THIS GRAPHIC WAS TRYING TO MAKE IS BY, IN A WORLD WHERE WE ARE WAITING TO, UH, RESPOND WHEN RESERVES ARE LOW AND WE ARE RESPONDING WITH LIMITED VISIBILITY, UH, THERE'S A, UH, THERE'S A POTENTIAL THAT WE WILL START NEEDING TO, UH, USE FIRM LOAD SHED OR START, UH, UH, RELYING ON FIRM LOAD SHED BEFORE MEANINGFULLY USING THE BACKUP SUPPORTED CURTAIL LOAD, UH, CURTAILMENT PROCESS.
I KNOW THE Q IS BUILDING, I PROBABLY HAVE MAYBE THREE SLIDES OR SO MORE.
NOW THIS NEXT SCENARIO IS AGAIN TALKING ABOUT, HEY, WHAT IF B SCLS WERE INSTRUCTED USING A NEAR TERM FORECAST, UH, AND HOW IT EXPECTS OPERATING MARGIN TO PLAY OUT AND WITH VISIBILITY SO WE KNOW WHAT THE LOADS CAN DELIVER.
AND SO WHAT YOU'LL NOTICE IS THE, UH, I'LL, I'LL, I'LL BUILD UP PACE OVER HERE.
SO THE TOP MARGIN, THE, THE TOP GRAPHICS IS STILL OPERATING MARGIN.
OPERATING CONDITIONS THAT WE HAD TO DEAL WITH WERE SIMILAR TO THE PREVIOUS SCENARIO.
NET METER LOADS WERE STILL CURTAILED AHEAD OF AN, UH, UH, UH, BY THE TIME AHEAD OF AN EEA ONE AHEAD OF, UH, WHEN WE HIT THE EEA ONE LEVELS.
BUT NOW YOU WILL NOTICE, UH, A CHANGE BECAUSE WE INSTRUCTED B SCLS BASED OFF OF A FOR FORECAST OF NEAR TERM CONDITIONS.
ALSO, WE WERE ABLE TO START INSTRUCTING CURTAILMENT OF B SCL L LOADS BEGINNING AROUND 225 MINUTES.
[01:00:01]
UH, WE, THE RESERVES AND REAL TIME HIT EEA ONE AND WE START SEEING THEIR RESPONSE COME, UH, UH, START BUILDING UP.WE DO STILL, UH, REACH EEA TWO LEVELS IN THIS PARTICULAR, UH, UM, UH, UH, ILLUSTRATION.
UH, YOU'LL SEE THE ERS AND NCLR COME IN, BUT BSCL LOAD WE KEEP, WE ARE ABLE TO CONTINUE INSTRUCTING BS B SCLS OR THE BACKUP SUPPORTED CURTAIL LEVEL LOADS AND BUILD UP THEIR RESPONSE, UH, AND KEEP BUILDING UP THEIR RESPONSE.
WE DO NOT REACH EEA THREE LEVELS AT ALL, AND WE ARE ABLE TO MANAGE AT LEAST THE, THE TIGHT OPERATING CONDITIONS THROUGH INSTRUCTING THE BSCL LOADS.
SO THAT'S, THAT'S WHAT THIS GRAPHIC IS TRYING TO SHOW US WITH THE, WITH NEAR TERM FORECAST OF NOT HAVING TO WAIT SO LATE, UH, FOR THE RESERVES TO DECLINE, MAY ALLOW US TO EFFECTIVELY USE THE VSCL LOADS AND, AND, UH, LIMIT THE AMOUNT OF FIRM LOAD SHED EXPOSURE.
NOW, THESE ARE THE TWO TOGETHER.
SO HERE'S THE, THE, EXACTLY THE TWO GRAPHICS THAT I SHARED.
UH, AND, AND REALLY THE, THERE ARE, LIKE WE MENTIONED, TWO DISTINCTIONS THAT WE HAVE DONE IN BOTH THESE CASES WHEN THE INSTRUCTIONS TO CURTAIL B SCL L STARTED AND WHAT, WHAT WAS OUR LEVEL OF AWARENESS OF BS SEALS, UH, WHEN THOSE INSTRUCTIONS WERE ISSUED? SO UNDER THE SAME ASSUMED CONDITIONS, UH, THE REAL TIME THRESHOLD CASE REACHES EEA THREE LEVELS AND FIRM LOAD SHED, WHILE THE NEAR TERM CASE, UH, REMAINED ABOVE E THREE LEVEL.
SO AGAIN, THE QUESTION IS WHY DID THE REALTIME THRESHOLD BASED CASE REACH FIRM LOAD SHED? AND WE'VE, UH, I MEAN, I'VE, I WON'T BE SURPRISED TO THE POINTS I'VE MADE.
I'VE BEEN, UH, THE CLOCK FOR THE B SCLS STARTED LATE.
IN THE CASE OF REAL TIME THRESHOLD, WE ONLY BEGAN INSTRUCTING WHEN THE OPERATING MARGIN WAS ALREADY LOW, LEAVING LITTLE TIME FOR THE AGGREGATE CURTAILMENT TO BUILD UP BECAUSE THERE WASN'T VISIBILITY.
UH, WE SPACED OUT THE SUCCESS SUCCESSIVE INSTRUCTIONS THAT WERE, UH, ISSUED TO AVOID TAKING A, UH, UH, CREATING A FREQUENCY RISK WITH TOO MUCH LOWER CURTAILING AT ONCE AND AS, AND THE AGGREGATE RESPONSE BUILT SLOWLY, THE NEO TERM CASE.
ON THE OTHER HAND, WE BEGAN ISSUING INSTRUCTIONS EARLIER.
THE INSTRUCTIONS WERE ISSUED CLOSER TOGETHER BECAUSE WE HAD A CLEAR UNDERSTANDING OF, UH, WHAT WE WOULD GET WHEN THOSE INSTRUCTIONS WERE ISSUED.
SO ULTIMATELY, THE AGGREGATE BSCL RESPONSE CAME IN SOONER AND STEADILY.
SO THIS IS AN ILLUSTRATIVE EXAMPLE.
I, I, UH, THAT, UH, AN EARLIER START TOGETHER WITH VISIBILITY ALLOWED US TO ALLOWED IN THIS PARTICULAR SITUATION TO REDUCE THE EXPOSURE TO FIRM LORD SHELL.
NOW I DO HAVE SOME SLIDES LATER ON WHERE WE TALK ABOUT WHAT A ALONE VIS.
SO THERE WERE TWO, LIKE I SAID, THERE WERE TWO NUANCES IN HERE, THE TIMING OF RESPONSE AND VISIBILITY.
I DO WANT TO ISOLATE WHAT IS THE IMPACT OF TIMING AND WHAT IS THE IMPACT OF VISIBILITY? AND I'LL GET TO THAT I WITH ONE MORE, UH, SORT OF ILLUSTRATION LATER ON IN THE SLIDES.
SO THIS GRAPHIC, UH, THIS SLIDE SUMMARIZES REALLY WHAT ARE THE OPERATIONAL IMPLICATIONS OF THE PARTICULAR SENTENCE THAT I HIGHLIGHTED IN PURE AS IT APPLIES TO BACKUP SUPPORTED CURTAIL LOAD.
THE TWO REQUIREMENTS, THE WHEN AND WHO TO DIRECT PRESENT TWO TYPES OF RISK, A TIMING RISK.
SO WAITING TO, FOR THE STATUTORY TRIGGER MAY LEAVE LESS TIME, UH, THAN THE, UH, WHAT THE CURTAILMENT RESPONSE TIME REQUIRES.
SO REQUESTED CURTAILMENT MAY NOT BE IN PLACE BEFORE FARM LOAD SHED IS NEEDED.
AND, UH, AND, AND I SPENT SOME TIME TALKING ABOUT THE LIMITATIONS OF USING THE UTILITY DIRECTED, UH, UH, PATH AS WELL.
IT ADDS, SORRY, IT ADDS ADDITIONAL COORDINATION.
UH, THERE IS ALSO THE POSSIBILITY OF TOO MUCH LOAD CURTAILING AT ONCE, FROM BREAKER, UH, FROM BREAKER OPENING, WHICH COULD CREATE FREQUENCY RISKS.
SO AT LEAST, UH, SEEING VERBATIM WHAT IS WRITTEN IN PUR, THE TIMING CONDITION MAY LEAVE TOO LITTLE TIME.
UH, FOR BS CUR, UH, BSCL CURTAILMENT TO BUILD UP THE UTILITY DIRECTED PATH MAY CREATE ITS OWN RISKS TIED MORE SO TO MISCOMMUNICATIONS, UH, DELAYS IN RESPONSE.
UM, AND THEY MAY NOT, AND, UH, ULTIMATELY DELIVER PRECISELY THE RESPONSE THAT COULD BE DELIVERED.
UH, AND, AND BOTH OF THESE RISKS CAN BE EXPECTED TO GROW AS THE VOLUME OF BSC ALERTS GROWS.
ALRIGHT, SO NOW WHERE DOES IT TAKE US FROM THIS OBSERVATION? REALLY, WHEN, WHEN WE THINK ABOUT CURTAILING B SCLS,
[01:05:01]
THERE ARE THREE OPERATIONAL REQUIREMENTS THAT SEEM TO MATTER THE MOST.SO AN INSTRUCTION SEQUENCE THAT CAN BEGIN EARLY ENOUGH WILL ALLOW US TO BUILD AND AGGREGATE BSCL CURTAILMENT BEFORE FORMULA SHED IS NEEDED.
USE THE SHORTEST PR, UH, PRACTICABLE CURTAILMENT RESPONSE TIME.
THIS IS TO SAVE, UH, DEFINE THE PARAMETERS SUCH THAT THE ONLY AMOUNT OF TIME THAT YOU PUT, UH, AS UH, NEEDED IS THE TIME IT TAKES TO CURTAIL THE LOAD.
THIS MEANS SHOWS THAT WE DON'T HAVE, ARD DOESN'T HAVE TO START INSTRUCTING TOO FAR IN ADVANCE OF ANY EA ONE OR OF ANY EA AND RESPONSE PRECISION.
SO DELIVER AND VERIFY THE MEGAWATTS.
SO IF T'S INSTRUCTING AND IF IT CAN KNOW FOR, IF IT CAN COUNT ON THAT RESPONSE BEING DELIVERED WITHIN THE TIME, THEN WE CAN, UH, DEVISE OUR PROCEDURES OR PROCESSES, UM, MORE APPROPRIATELY AND REDUCE THIS RISK TIED TO, UH, UH, REDUCE THE RISK OF FIRM LOAD SHED.
SO TOGETHER THESE THREE, UH, AT LEAST, UH, OR REQUIREMENTS DEFINE WHAT OPERATING, UH, WHAT IS THE NEEDED OPERATING OUTCOME.
UH, I WILL PAUSE EXACTLY HERE.
I OPENED THE FLOOR UP IF THERE ARE QUESTIONS OR FEEDBACK FOR US.
THANK YOU, UH, NED, YOUR FIRST STEP.
AND I APOLOGIZE, I'VE BLOWN UP THE CHAT A COUPLE TIMES ALREADY.
UM, SO, UH, ON THIS LAST POINT, JUST TO START HERE, NITKA ON THE RESPONSE TIME, UM, GIVEN THAT WE'RE TALKING ABOUT BACKUP SUPPORTED CURTAIL LOAD, I'D RECOMMEND THAT, UM, IN THE RESPONSE TIME Y'ALL LOOK AT THE TIMING TO SWITCH TO BACKUP GENERATION, NOT NECESSARILY THE CURTAILMENT TIME, AND, YOU KNOW, FACTOR THAT IN IT.
UH, AND I THINK YOU CAN PROBABLY THEN DIAL IN ON HOW YOU ADDRESS EACH INDIVIDUAL LOAD THAT YOU CURTAIL AND DO THAT MORE PRECISELY AND PROVIDE AN INCENTIVE FOR FASTER CAPABILITIES TO SWITCH TO BACK UP JEN.
UM, WHICH I THINK GETS TO ERIC'S POINT HE MADE EARLIER ABOUT WE WANT TO PROVIDE POSITIVE INCENTIVES TO MARKET PARTICIPANTS TO, UM, YOU KNOW, OPERATE THE MOST RELIABLY AND RESILIENTLY THAT THEY, THAT THEY CAN.
UM, ALONG THAT SAME LINE OF THINKING ABOUT SETTING OUT GOOD INCENTIVES, UM, YOU KNOW, THERE ARE CURABLE LOADS THAT WE PAY AND THERE ARE THE CURTAIL BILL LOADS THAT THROUGH SENATE BILL SIX DON'T GET PAID.
AND AS A GENERAL PRINCIPLE, IT MAKES SENSE TO USE THE THINGS THAT YOU PAY TO CURTAIL BEFORE YOU TAKE FROM THE ONES YOU DON'T.
UM, SO I'D RECOMMEND THAT AS WE'RE LOOKING AT THE, THE, YOU KNOW, THE WHOLE ENCHILADA OF, UH, YOU KNOW, EMERGENCY OPERATIONS LOOK AT USING THE STUFF THAT WE PAY FOR FIRST AND FOREMOST IN THAT, THAT ORDER OF OPERATIONS.
AND I THINK MICHAEL HAD ASKED ABOUT, YOU KNOW, YEAH, WE DEPLOY ERS AT PRC BELOW 3000 AND, UM, I, I SUSPECT THAT ALL OF THOSE THINGS GET THROWN UP IN THE AIR WHEN WE ARE TRYING TO EVALUATE HOW TO, HOW TO MANAGE IT.
AND THEN THE, UM, THE, THE THIRD ITEM, AND I DON'T WANT TO DERAIL THIS CONVERSATION
THE STATUTE SAYS YOU HAVE TO USE IT AFTER YOU'VE, UH, EXHAUSTED YOUR NON FREQUENCY RESPONSIVE RESERVES.
AND I SUSPECT THAT THERE IS SOME NEED TO ACCOMMODATE THAT IN OUR ANCILLARY SERVICE METHODOLOGY AND ANCILLARY SERVICE DEMAND CURVES.
UM, ERIC'S LAUGHING
I JUST WANNA PLANT THE SEED AND WE CAN DISCUSS THAT LATER.
BUT I THINK THAT THERE, THERE'S PROBABLY SOME COORDINATION TO SUPPORT THIS STATUTORY REQUIREMENT IN THE WAY THAT WE, UM, RELEASE ANCILLARY SERVICES UNDER REALTIME CO OPTIMIZATION.
I THINK SLIDE 19 PROBABLY IS A GOOD PLACE TO, UH, ANSWER, UH, ASK THE QUESTION.
SO JUST FOR COMPLETE CLARITY, A AS AN EXAMPLE FOR A-B-S-C-L, IF THERE'S A THOUSAND MEGAWATT LARGE LOAD THAT HAS 501 MEGAWATTS OF BACKUP GENERATION THERE CURTAILMENT INSTRUCTION FOR THAT BSCL IS 501 MEGAWATTS, THE OTHER 499 WOULD BE SUBJECT TO FIRM SH FIRM LOAD SHED LATER IF CONDITIONS CONTINUE TO DETERIORATE.
IS THAT CORRECT? NATHAN, YOU WANNA TAKE THAT ONE? YEAH, I MEAN, I THINK, UM, OUR PERSPECTIVE IS THAT THE STATUTE SETS OUT A TRIGGER THAT APPLIES TO THE ENTIRE LOAD.
SO THE, THE ENTIRE LARGE LOAD WOULD BE SUBJECT TO GREG CURTAILMENT.
IF IT'S GOT BACKUP GENERATION, IT CAN CHOOSE TO USE THAT BACKUP GENERATION
[01:10:01]
TO SERVE THAT AMOUNT OF ITS LOAD.IF IT DOESN'T, THEN THAT LOAD IS EXPOSED, UM, TO ABSOLUTE CURTAILMENT.
IF YOU GET A, AS A-B-S-C-L, YOU GET A CURTAILMENT INSTRUCTION AND EEA ONE OR TWO, YOU HAVE 501 MEGAWATTS OF BACKUP GEN, A THOUSAND MEGAWATTS OF A LARGE LOAD.
THE CURTAILMENT INSTRUCTION IS BASICALLY OPEN THE BREAKER AND YOU CAN SERVE 501 MEGAWATTS FROM WITH YOUR BACKUP GEN AND THE, THE REST IS CURTAILED TO MAKE SURE WE'RE CLEAR.
SO IN YOUR EXAMPLE, I'M GOING TO ASSUME THERE ARE TWO ANSWERS POSSIBLE.
SO I'M GONNA ASSUME THIS SITUATION WHERE THE BACKUP GENERATION THAT YOU DEFINED AND THE SIZE YOU DEFINED AS FINITE, ALL IT CAN DO IS, UH, 499 MEGAWATTS.
IT'S, UH, THE CONTROL SCHEME IS SUCH WHERE ONCE YOU INSTRUCTED ALL 4 99 COMES ON AT THE SAME TIME.
FOR US, WHAT WE ARE TRYING TO BUILD HERE IS A SYSTEM THAT IS AWARE OF LARGE LOADS, AT LEAST IN THE VISIBILITY SCENARIO.
IF IT'S A THOUSAND MEGAWATT LOAD AND THE SYSTEM NEEDS, LET'S SAY 2000 MEGAWATTS OF CURTAILMENT, IT IS RANDOMLY GOING TO SELECT LOAD.
AND IF THIS LET'S GO, THIS LOAD GETS SELECTED AND IT REALLY CAN ONLY FULLY CURTAIL, THEN THE FULL INSTRUCTION OF THOUSAND GOES OUT.
SO IT'S, IT'S PRORATED BASED ON THE NEED OF WHAT NEEDS TO BE SHED.
AND WHAT THE CAPABILITY IS ALSO.
'CAUSE I WAS GONNA SAY THERE IS A POTENTIALLY ANOTHER WORLD WHERE YOU CAN PROBABLY PULL, UH, THE LOAD OFF IN BLOCKS MM-HMM
AND IF WE ARE A, WE ARE HAPPY TO MODEL THOSE BLOCKS IN OUR TOOLS.
AND THEN WHEN WE RANDOMLY SAMPLE, WE MAY JUST PULL A BLOCK AND SAY, I NEED 2000.
THIS LOAD CAN GIVE ME 250 MEGAWATT BLOCK.
AND THAT'S JUST 250 INSTRUCTION THAT YOU GET.
AND THE REST OF THE LOAD IS STILL ABLE TO BE ONLINE CONSUMING.
AND THEN ON THIS SLIDE, JUST TRYING TO CLARIFY WHAT YOU'RE TRYING TO TELL US.
BAD SIDE OR LEFT SIDE? BAD RIGHT SIDE.
WE DON'T WANNA DO THE LEFT SIDE.
'CAUSE THAT WOULD JUST, I'M JUST THINKING AGAIN THROUGH THAT EXAMPLE.
THAT WOULD BE SUPER CONFUSING.
YOU GET AN INSTRUCTION FOR A PORTION OF YOUR LOAD, YOU START TO TURN UP YOUR BACKUP GEN, AND THEN BEFORE THAT EVEN HITS THE LINE, YOU'RE TOLD TO DUMP, UH, THE REST OF YOUR LOAD UNDER A FIRM LOAD SHED, UH, INSTRUCTION.
SO THAT'S SO, SO CAREFUL ABOUT IT.
SO MAYBE ACTUALLY YOU'VE, YOU'VE GONE MAYBE THREE OR FOUR STEPS IN YOUR ASSUMPTIONS IS HOW I WOULD PUT IT.
NOW, IF YOU WANT TO, MAYBE LET'S DO THIS.
I HAVE, IF MY SECOND LAST SLIDE TALKS ABOUT WHAT TO DO WITH LOAD THAT IS EXPOSED TO CURTAILMENT UNDER SP SIX FROM A FARM LOAD SHE PERSPECTIVE.
'CAUSE IN YOUR ASSUMPTION, I THINK YOU DO, THE LINE OF PORTION OF MY LOAD IS SUBJECT TO SP SIX, THE REST OF IT IS SUBJECT TO FARM LOAD.
I'M NOT SURE THAT IS CUR, THAT MAY NOT NECESSARILY NEED TO BE THE CASE.
SO, UH, SO HOLD THAT LINE OF THOUGHT JUST FOR A MINUTE BECAUSE, UH, IN OUR MINDS, MAYBE I'LL GIVE YOU A SMALL PUNCHLINE.
IF A LOAD IS ABLE TO BE CURTAILED AHEAD OF E EEA THREE, IT'S A FAIR QUESTION TO ASK, SHOULD IT BE EXPOSED TO FARM LOAD SHED? AND THAT IS, THAT'S THE TAKEAWAY FROM WHAT YOU'RE TRYING TO TELL US HERE IS IT'S A HERO YOU WOULD LIKE MORE, MORE LEAD TIME YEAH.
TO ISSUE THESE CURTAILMENT INSTRUCTIONS.
UH, I DO THINK, UH, NED RAISES A GOOD POINT.
I'M JUST CURIOUS HOW YOU GUYS SQUARED THE REQUIREMENT ASB SIX TO CUR UTILES, UM, AFTER NON-RESPONSIVE, UH, SERVICES HAVE BEEN DEPLOYED.
SO I'M JUST CURIOUS IF YOU GUYS HAVE THOUGHT ABOUT THAT AND IF YOU DISAGREE WITH THAT INTERPRETATION.
SO THE PICTURE ON THIS SIDE OF YOUR, UH, OF THE SLIDE DECK, SO THE LEFT SIDE IS TRYING TO READ AS BASICS FOR BACKUP SUPPORTED AS WRITTEN.
SO INSTRUCT B SCLS AFTER ALL MARKET SERVICES WAS DEPLOYED, THE STAND STANDIN IS EEA LEVEL TWO.
SO INSTRUCT THEM AFTER YOU ARE ALREADY IN EEA TWO.
AND, UM, AND THAT IS A, UH, AND YOU HAVE NO VISIBILITY, SO YOU DON'T KNOW WHAT YOU WILL GET.
THAT IS THIS PICTURE THAT, UH, UH, UH, TO, UH, UH, WHAT YOU POTENTIALLY CAN LEAD INTO IS A SITUATION WHERE BSCL CURTAILMENT DOESN'T BUILD UP.
[01:15:01]
THREE NOW, FIRM LORD SHED IS EXPOSED.AND YOU ARE RIGHT IN, IN THAT SITUATION.
WHAT IS THIS? IF YOU HAVE A SINGLE LARGE LOAD WHICH HAS 50% BACKUP GEN, WHAT ALL IS IT EXPOSED TO? AND THAT'S, I THINK IT'S AN EXACT FAIR POINT TO MAKE ON THIS SIDE OF THE GRAPHIC, BUT IT MAY NOT NECESSARILY BE CONFUSING IF YOU ARE ON THIS SIDE OF THE WORLD WHERE KOTS ABLE TO, IN INSTRUCT IN ANTICIPATIONS AHEAD OF BEING THAT LOW, UH, AS FAR AS RESERVES GO.
AND OF COURSE THE, IN OUR MIND THE ULTIMATE GOAL, AT LEAST THE WAY OUR TAKEAWAY FROM SB SIX WAS REDUCE EXPOSURE OF FIRM LOAD SHARE.
SO REDUCE EXPOSURE TO RESIDENTIAL AND OTHER CUSTOMERS.
THERE IS A WAY WE CAN EFFECTIVELY MANAGE THAT IF WE ARE ABLE TO START PLANNING AHEAD OF TIME AND CAREFULLY TAKE THIS LOAD OFF.
AND THAT'S THE, THAT WAS PROBABLY THE TAKEAWAY THAT I WAS TRYING TO GET TO BY SHOWING THIS COMPARATIVE GRAPHIC.
THIS IS WHERE, THIS IS ONE A POTENTIAL, UH, OUTCOME OF OUR SB SIX IS THIS IS A DIFFERENT WORLD ALTOGETHER.
AND, AND BILL, PERHAPS I CAN PROVIDE A BIT MORE COLOR IN TERMS OF THE INTERPRETATION SIDE OF THINGS.
UM, I MEAN, I THINK WHAT YOU'RE ZEROING IN ON IS THAT WE DO SEE A PROBLEM WITH A LITERAL READING OF THE STATUTE, UM, IN THE SENSE THAT IF YOU HAVE TO WAIT UNTIL ALL THOSE, UM, NON-RESPONSIVE, YOU KNOW, RESERVES ARE, ARE FIRST DEPLOYED, THAT PUTS US IN A, A TOUGH SPOT.
AND SO I THINK, YOU KNOW, PART OF TODAY'S ASK IS WHAT DO WE DO ABOUT THAT? UM, BECAUSE THIS REALLY ISN'T AN OPTIMAL PLACE TO BE AND WE NEED TO FIGURE OUT HOW TO EFFECTUATE CURTAILMENT.
BUT WE REALLY SEEM TO HAVE A PRETTY SIGNIFICANT OBSTACLE HERE TO DOING THIS IN A REASONABLE WAY FROM OUR PERSPECTIVE.
UH, NEXT QUESTION WAS FOR BROTH.
HE DID AT LEAST TYPE THE FIRST PART OF THE QUESTION IN WAS, OOPS, I LOST IT.
HOW LONG IS THE FORECAST IN TERMS OF HOURS THE NEAR TERM FORECAST DESCRIBED? HEY MATT, CAN YOU HEAR ME? YEP, GO AHEAD.
YEAH, I HAD A COUPLE OF QUICK QUESTIONS.
FIRST WAS, UH, IS THERE A DEFINITION FOR A NEAR TERM FORECAST OR, YOU KNOW, IFIED IN TERMS OF NUMBER OF HOURS AHEAD? HOW, HOW IS OUR CUT DEFINING THAT? WHEREAS I ALMOST WANT TO ANSWER AND NOT ANSWER 'CAUSE THAT WOULD BE GETTING INTO THE TECHNICAL DETAILS.
UH, SO TODAY, RIGHT NOW, THE, UH, UH, I, THE, MY VISION IS ASSUME I HAVE EYES AND I'M ABLE TO DO IT.
I CAN GIVE YOU EXAMPLES WHERE TO SUPPORT MY ASSUMPTION.
I, I HAVE A TWO HOUR OUT OR AN INTRA HOUR FORECAST THAT WE PUBLISH EVERY FIVE MINUTE.
IT GIVES US EYES TWO HOURS OUT.
I HAVE 168 HOUR ROLLING FORECAST.
ALSO, THERE ARE WAYS WE CAN USE FORECAST TOOLS FOR LOAD WIND, SOLAR, AND BUILD, UH, BUILD OUR, UH, ESTIMATIONS OF MARGINS.
BUT THAT'S AT LEAST NOT WHAT I WANT TO DELVE ON TODAY.
AT SOME POINT, WILL YOU BE COMING UP WITH CERTAIN, UH, QUANTITY OF OURS? BECAUSE IT'S OBVIOUSLY AS A LARGE LOAD, IT'S IMPORTANT FOR US TO KNOW WHAT WE SHOULD BE ALSO LOOKING OUT FOR, RIGHT.
ON OUR END, UH, TO BE MORE, TO HAVE MORE SITUATIONAL AWARENESS.
UH, THE SECOND QUESTION I HAD WAS IN TERMS OF, UH, YOU KNOW, RANDOMLY SELECTING THESE NET METER LOADS, RIGHT? UH, I'M JUST TRYING TO UNDERSTAND IF THERE IS ANOTHER WAY TO DO THIS THAN RANDOMLY SELECT THESE NET METER LOADS, MAYBE BASED ON SYSTEM TOPOLOGY OR, YOU KNOW, WHICH LOAD HAS HIGH PROBABILITY TO EASE THE, YOU KNOW, CONDITIONS THAT YOU ARE ENVISIONING THAT ARE COMING OUT, UH, BASED ON SOME SYSTEM STUDIES THAT YOU CAN DO, UM, PROBABLY TO CERTAIN FREQUENCY RIGHT DAY AHEAD OR MAYBE IN SOME, SOME LEVEL OF FREQUENT STUDIES THAN JUST RANDOMLY PICKING THESE LOADS.
SO MAYBE I'LL ANSWER THAT ONE.
I MEAN, TO THE, THIS GETS BACK TO MARTHA'S QUESTION EARLIER THAT TO THE EXTENT THAT YOU WANT TO CONTROL BECOME ACL R, AND THEN YOU OFFER IN AT A, YOU KNOW, RELATIVE PRICE, THEN, YOU KNOW, AND YOU'RE AT A BETTER SPOT ON THE SYSTEM.
OR, YOU KNOW, YOU WANT TO BE AT 4 99, 4 9 9 $9 OR SOMETHING LIKE THAT.
YOU, YOU CAN DO THAT BY BECOMING ACL R.
AND TO THE EXTENT YOU'RE ACL R, I GUESS YOU PROBABLY DON'T FIT INTO THIS BUCKET AT ALL.
[01:20:01]
YOU KNOW, THAT'S, THAT'S THE WAY TO DO THAT KIND OF THING.BUT WHAT I MEAN IS, I MEAN, OBVIOUSLY THESE ARE FIRM LOADS AND YOU KNOW, THE, UNLESS, UH, THE LOADS NEED TO CURTAIL, THEY DON'T WANT TO CURTAIL IT.
THESE ARE, THESE ARE FIRM LOADS THAT I'M TALKING ABOUT.
SO IS CAN WE WORK ON A METHODOLOGY ON UNDERSTANDING, YOU KNOW, THE TRANSMISSION CONSTRAINTS OR THEAS IN GEOGRAPHICAL REGIONS AND HENCE THAT LEADS TO THE RATIONAL OF CURTAILING THESE LOADS VERSUS RANDOMLY SELECTING THE LOADS.
RIGHT? FOR, UH, I'M JUST SPECIFICALLY ADDRESSING THE NET METER LOADS HERE.
THAT'S, THAT'S WHERE I'M GOING HERE RATHER THAN JUST NOT CLR AND THE FLOW PRICE AND NOT, NOT THOSE THINGS HERE.
HAR, MAYBE I CAN, AGAIN, UH, NET METER LOADS, UH, THERE ARE TWO POTENTIAL TYPES OF EMERGENCIES MAYBE THAT WE CAN PROBABLY RIGHT.
THINK THROUGH, RIGHT? IF IT'S A SYSTEM WIDE CAPACITY ISSUE MM-HMM
THEN REALLY IT'S ABOUT TAKING LOAD OFF THE SYSTEM AND MAKING, UH, SUPPLY AVAILABLE OR MAKING, TAKING LOAD OFF THE SYSTEM.
OUR POSITION SO FAR HAS BEEN, UH, RANDOM SELECTION.
IT, IT MAY BE OKAY NOW, I THINK YOUR POINT AS WELL, BUT CAN YOU LOOK AT THE SYSTEM AND SEE WHAT RELIEF YOU WILL GET? YES.
SO I SEE, UH, A CLEAR PATH TO DOING THAT WITH A TRANSMISSION SITUATION WHERE I KNOW WHAT'S ACTIVELY GOING ON MM-HMM
AND WHEN I'M IN A TRANSMISSION EMERGENCY, UH, WE CAN THINK THROUGH IF THERE ARE WAYS AT SYSTEM FOR SYSTEM WIDE SCARCITY, IF IT'S POSSIBLE SO FAR, UH, YOU KNOW, WHEN, UH, EVEN WHEN WE DO FIRM LOAD SHED TODAY, WE DON'T, UH, TAKE THOSE INTO ACCOUNT.
WE ASK, UH, WE INSTRUCT AND THEN WE WAIT TO SEE HOW THE RESPONSE TO THE INSTRUCTIONS HAS EVOLVED, UH, CHANGES THE OPERATING CONDITIONS.
EVEN FOR SYSTEM-WIDE SCARCITY, RIGHT? YOU HAVE TSP SHARE, YOU JUST LET TSP KNOW THEIR SHARE AND THEY'LL KIND OF WORK ON IT, RIGHT? SO THAT CAN PROBABLY ALSO WORK IN FOR NET METER LOAD BUCKETS, RIGHT? SO TSPS HAVE THEIR SHARE AND IF THERE ARE CERTAIN NET METER LOADS IN THAT TSP, THEY'LL PROBABLY GO AND CURTAIL THEM, RIGHT? IF THEY HAVE MORE NET METER LOADS IN CERTAIN TSP, OBVIOUSLY THERE IS NOTHING THEY CAN, THEY CAN PROBABLY PROPORTIONALLY CURTAIL THEM.
YOU SEE, I MEAN, I I'M TRYING TO PUT A RATIONAL ON HOW THESE CAN BE DONE VERSUS RANDOM SELECTION.
SOMETHING THAT WE ALL CAN PROBABLY COME UP WITH, WE CAN THINK ABOUT IT MAKES.
AND, UH, WHEN WE COME BACK NEXT TIME, SHARE OUR THOUGHTS.
ALL RIGHT, NEXT UP BRIAN SAMS THAT LAST QUESTION REALLY TOUCHED ON WHAT I WAS ASKING ABOUT GEOGRAPHIC RESTRICTIONS ON, UH, LOAD.
SHE SOUNDS LIKE YOU'RE THINKING ABOUT IT AND WE'LL TALK ABOUT IT MORE, LIKE DAN ALLUDED TO.
THERE ARE, LIKE I SAID, THERE IS CERTAIN THINGS LIKE WHEN YOU ARE IN A TRANSMISSION SITUATION AND UH, ISSUE A TRANSMISSION RELATED EMERGENCY WHERE OUR TOOLS EVEN TODAY HELP US NARROW DOWN THOSE INSTRUCTIONS.
SYSTEM WIDE SCARCITY IS DIFFERENT IN OUR MIND, BUT WE CAN CERTAINLY SPEND SOME TIME MORE THINKING ABOUT IT BEFORE NOVEMBER 6TH THAN PROVIDE A RESPONSE WHEN WE COME BACK.
AND JUST TO PROVIDE SOME MORE CONTEMPORANEOUS FEEDBACK.
I LIKE THE IDEA OF SOME, YOU KNOW, RANDOM, UH, ALLOCATION TO, TO DIFFERENT LOADS.
'CAUSE I DON'T ALWAYS WANNA BE THE FIRST IN LINE.
UM, BUT I ALSO DON'T WANNA BE PART OF, UH, UH, AN ISSUE THAT THAT CAUSES A, A FREQUENCY UPSET.
NO, WE'VE, AT LEAST WHEN WE'VE TALKED ABOUT RANDOM, SOMETHING ELSE WE'VE TALKED ABOUT IS WE MAY NOT BE ABLE TO CHANGE OUR INSTRUCTIONS WHILE IN THE MIDDLE OF AN EVENT, BUT WE CAN, THOSE THAT WERE INSTRUCTED FIRST TIME CAN POTENTIALLY BE PUT IN THE BACK OF THE LINE WHEN WE GO BACK TO SELECTION.
THOSE SORT OF THINGS DID COME TO OUR MIND AT LEAST AS IDEAS OF HOW THINGS COULD BE DONE WHEN WE HAVE THAT BIG OF A FLEET.
AND MY COMMENT DOESN'T JUST APPLY TO THE, UH, THE B SELS.
IT'S ALSO THE, YOU KNOW, NET METER LOADS TOO.
UH, THANK YOU SO MUCH AND, UH, DE I REALLY APPRECIATE THIS ON THE, ON THE SLIDE 19, I WAS WONDERING WITH REGARD TO ERS, MY RECOLLECTION IS, IS THAT THAT CAN BE DEPLOYED AS EARLY AS 3000, UH, PRC.
SO IT WOULD SEEM LIKE YOU WOULD MOVE THAT GREEN BAR SIGNIFICANTLY OVER TO THE LEFT TO START DEPLOYING POTENTIALLY BEFORE THE, UH, NET METERED LOAD.
IS THAT CORRECT? SO ERS MAY BE
[01:25:01]
DEPLOYED BELOW 3000, MUST AND WILL BE DEPLOYED BELOW EEA ONE.SO AT LEAST WHEN I MODELED THIS, I USED, UH, UH, UH, BELOW E YEAR TWO.
UH, REMEMBER MICHAEL, SOMETHING ELSE TO KEEP IN MIND, THIS IS A STACK OF ERS AND NCL LRS.
SO SOME PORTION OF ERS CAN CERTAINLY COME EARLIER OR SOME PORTION OF THIS RESPONSE CAN START EARLIER, BUT QUITE A, UH, BUT THE, THE NC LRS WOULDN'T.
SO JUST THAT WOULD PROBABLY BE SOMETHING TO BE AWARE OF, UH, THE WAY I'LL PAUSE.
YEAH, NO, THAT, THAT MAKES SENSE.
AND THEN I GUESS THE OTHER THING THAT I WAS WONDERING ABOUT IS WITH REGARD, UH, TO THE AMOUNT OF RESPONSE THAT, THAT THIS IS, UM, THAT INDICATING IS THAT REFLECTING THE SIGNIFICANT REDUCTION OF ERS THAT ERCOT HAS MODELED AS A RESULT OF THE IMPLEMENTATION OF NPRR 1337? SO I WILL PUT IT TO YOU THIS WAY.
I ASSUMED SOME AMOUNT OF MEGAWATTS WERE STILL AVAILABLE AND THAT IS WHAT CAME OFF.
I DID NOT, I DID NOT WANT TO MAKE THIS A DISCUSSION ABOUT ERS.
THIS IS MORE OF A TIMING RESPONSE OF B SCLS.
SO, UH, SO TO THE EXTENT THAT, UH, ERS CAN CHANGE, THINGS CAN CHANGE, I SIMPLY ASSUMED CERTAIN MEGAWATTS COULD STILL BE INSTRUCTED AND THEY CAME OFF AT EA TOO.
UM, YEAH, I'VE KINDA HAD SOME QUESTIONS AROUND THE HOW ERS IS BEING USED IN THIS AND THE QUANTITIES.
I DON'T WANT TO, YOU KNOW, NITPICK THE EXAMPLES 'CAUSE IT'S, IT'S, IT'S AN ILLUSTRATION.
IT'S NOT MEANT TO BE, I THINK, YEAH, I, PERFECT.
I WANNA SAY OFF THE ERS HER OPENING SLIDE SAID, WE'RE NOT GONNA GO INTO THE DETAILS OF THESE THINGS, SO JUST CONSIDER SOMETHING AS PUSHED AND HAPPENS IN THE SEQUENCE.
BUT I MEAN, IF IT'S A BRIEF ONE, WE CAN GO FOR IT.
BUT I DON'T WANNA GET INTO ERS 'CAUSE WE TALKED ABOUT IT.
NO, I'M, I'M ON, I I WAS ALLUDING TO HIS QUESTION THAT HE JUST ASKED.
UM, SO THIS I'M LOOKING AT IS STILL BEING, UH, A SLOW BURN EVENT.
UH, VERY MUCH SO WE HAVEN'T KIND OF ADDRESSED THE, THE FAS BURN NATURE OF THIS AT ALL.
UM, AND I'M ALSO LOOKING TO HOW WE'RE GONNA BE BUCKETING THESE.
I THINK IT'D BE VERY, VERY CUMBERSOME OR LIKE COMPLICATED ON THE OPERATOR STANDPOINT IF THIS IS GONNA BE TAILORED ON A RESOURCE BY RESOURCE BASIS.
I THINK MAYBE SOMETHING MORE LIKE ERS 10 VERSUS 30, LIKE YOU'VE GOT A BUNCH, YOU KNOW, WE'LL GET, HAVE A 10 MINUTE RESPONSE, YOU HAVE A BUNCH, YOU KNOW, THAT MAY BE LONGER.
SO WE CAN KIND OF TAILOR THAT AND HOLD THESE DIFFERENT BUCKETS OUT FOR DIFFERENT DEPLOYMENT MECHANISMS. THINGS ALONG THOSE LINES WOULD BE MAYBE A, UH, A MORE POIGNANT, UH, DE UH, EASIER WAY TO DO THAT.
UM, AND THEN, UM, I'M ALSO THINKING THAT THIS, YOU KNOW, THERE'S NOT NECESSARILY NEEDS TO BE A, A SINGLE TRIGGERING POINT.
UH, THAT'S LIKE THE SAME THING WITH NON-CONTROLLABLE LOADS.
YOU'VE GOT A 10 MINUTE TRIGGER THAT WE COULD, OPERATORS WOULD USE AND KIND OF A SLOW BURN SITUATION WHERE THEY'RE WORRIED ABOUT, UH, THE DECLINE OF FREQUENCY OR THE DECLINE OF, UH, PRC.
AND THEN YOU ALSO HAVE A FASTER TRIGGER.
AND SO SOMETHING LIKE THAT COULD POTENTIALLY BE IMPLEMENTED WHERE THE KIND OF QSC IS RESPONSIBLE FOR, THESE ARE MONITORING FREQUENCY AND WHEN THEY SEE IT GETS TO A CERTAIN LEVEL, THERE'S UH, AN ESTIMATED, YOU KNOW, PROPORTIONAL RESPONSE THAT THEY'RE EXPECTED TO PROVIDE, UM, AND THINGS LIKE THAT.
SO I THINK THERE'S, THERE'S OTHER WAYS THAT WE CAN BE DOING THIS THAT COULD MAKE ERCOT MORE COMFORTABLE WITH WAITING TO, IT'S BEHIND THE KIND OF MORE TRADITIONAL DEPLOYMENT METHODOLOGIES THAT WE'VE GOT AND ALL THE PAID SERVICES THAT WE'VE GOT, UM, ALREADY, UH, OUT THERE TO BE USED.
SO I DO THINK IT'S IMPORTANT THAT WE RELY ON THE EXISTING SERVICES.
UM, AND THIS IS REALLY KIND OF FOR EMERGENCIES WHEN WE THINK THAT THOSE ARE NOT GOING TO BE, UM, ABLE TO SOLVE THE SITUATION.
AND FOR INSTANCE, LIKE WITH THAT NEAR TERM FORECAST, WHEN IT'S SEEING THAT WE'RE GOING INTO, YOU KNOW, PREDICTING THAT WE'RE GONNA GO BELOW 2000 OR EVEN BACK BEFORE THAT WHEN WE'RE DEPLOYING THE NET METERED GUYS, IS THAT ESTIMATING, YOU KNOW, ZERO RESPONSE FROM RRS AND REGULATION AND HOW IS THAT BEING KIND OF, UH, GOING THROUGH AND BEING HELD OFF? UM, IT WOULD BE, IT WOULD BE GOOD TO SEE KIND OF THAT MAYBE THAT AN UPDATED PRESENTATION TO HAVE THE, THE FORECAST ALSO ON THIS LINE.
SO WE KIND OF HELPS US THINK THROUGH HOW THE OPERATORS ARE GONNA BE SEEING THE SITUATION.
UM, JUST A LOT OF FRUIT FOR THOUGHT THERE.
NO, QUITE A BIT OF POINTS THERE TO COVER.
YOU KNOW, LIKE WITH MOST EXAMPLES, IF YOU'RE GONNA ILLUSTRATE A POINT, YOU HAVE TO KIND OF ILLUSTRATE THE, THE PART OF THE PROBLEM THAT
[01:30:01]
YOU ARE TRYING TO POINT TO.AND I THINK WE'VE TRIED TO DO THAT.
WE PROBABLY SHOULDN'T HAVE PUT ERS ON HERE, YOU KNOW, BECAUSE THAT WASN'T THE POINT.
THE POINT WAS THE EARLIER AND THE MORE DIRECTLY WE CAN DO THIS, THE LESS LIKELY IT IS.
WE'RE GONNA HAVE TO SHED THE RED STUFF BEFORE WE CAN, CAN TAKE ADVANTAGE OF THE, THE, I GUESS THAT'S A BLACK LINE.
I THINK IT'S GONNA BE IMPORTANT TO BE PRESCRIPTIVE AND NOT OVERLY COMPLICATE THIS AS WELL.
I DON'T WANT LIKE IF S HAVING TO TRACK INDIVIDUAL CAPABILITIES SITE BY SITE BASIS AND WHICH ONES CAN, SO, SO MAYBE CAN I ADDRESS THAT? YEAH.
THE CONTROL ROOM DOESN'T SELECT UNITS.
IT INSTRUCTS MEGAWATTS TOOLS MAKE THE INSTRUCTIONS FOR THEM BASED OFF OF CAPABILITIES OF WHO IS AWARDED IN REAL TIME.
SO AS FAR AS MANAGING THIS SORT OF INSTRUCTIONS GO, THAT SORT OF A MODEL WOULD BE THE MODEL TO HELP THE OPERATORS IS MAKING THEM AWARE OF THE SITUATION AND WHAT ACTIONS NEED TO BE TAKEN.
AND THEN LETTING THEM PUSH THE BUTTON OFF, HEY, TAKE THE ACTION.
AND THEN THERE ARE TOOLS THAT DETERMINE WHICH LOADS TO INSTRUCT.
SO AT LEAST THOSE COMPLEXITIES ARE AGAIN, IN THE WEEDS OF THE HOW AND THOSE CAN BE MANAGED AS FAR AS MAKING SURE THE OPERATORS ARE ABLE TO TAKE ACTIONS WITH APPROPRIATE AWARENESS.
AND AGAIN, THE FO LIKE NAN MENTIONED, THE FOCUS OF TODAY WAS NOT THE, HOW THE FOCUS OF TODAY WAS, WHAT IS THE LANGUAGE AND WHAT ARE THE OPERATIONAL IMPLICATIONS OF THE LANGUAGE IF WE APPLY IT VERBATIM TO SHARE THOSE OUT WITH YOU ALL.
AND IN MY DEFENSE, IF I HAD NOT PUT ERS AND NCS THERE, SOMEBODY WOULD'VE POINTED OUT YOU HAVE THOSE, DON'T YOU? SO, UH, I MEAN, UH, AGAIN, THE PURPOSE OF THIS WAS TO MAKE A POINT AROUND, UH, IF I AM AWARE OF A SITUATION COMING AHEAD OF TIME AND I USE THAT TO TAKE INSTRUCTIONS, I MAY BE ABLE TO AVOID NEEDING A FIRM LOAD SHED AT ALL.
UH, MARTHA HENSON WITH ENCORE BACK ON SLIDE 13 WHERE IT TALKS ABOUT THE LIMITATIONS OF ROUTING BSCL THROUGH THE UTILITIES.
I, AND I THINK THIS QUESTION MAY BE MORE SO FOR NATHAN THAN NITKA, BUT, UM, HAS, IS ERCOT LOOKING AT ANY ALTERNATIVES TO THAT APPROACH WHERE THE INSTRUCTION COULD BE COMMUNICATED DIRECTLY TO THE LARGE LOAD? OR DO YOU, IS IT ERCOT POSITION THAT YOU'RE SOMEWHAT LOCKED INTO THE UTILITY BEING THE INTERMEDIARY BECAUSE OF THE STATUTORY LANGUAGE? YEAH, I MEAN, I THINK THAT'S ONE THING WE'RE HIGHLIGHTING HERE IS THE OBSTACLE, UM, THAT WE HAVE WITH THE, WITH THE WAY THE STATUTE HAS PRESENTED THE COMMUNICATION PATH.
UM, AND THAT, UH, THERE'S CERTAINLY DOWNSIDES TO THAT, UM, BOTH IN TERMS OF THE POTENTIAL FOR MISCOMMUNICATION, THE, THE LIKELIHOOD OF SOME DELAY THERE.
AND THAT'S JUST NOT REALLY OPTIMAL FOR TELL OF LARGE AMOUNTS OF LOAD.
SO, UM, I THINK WE WANNA HIGHLIGHT THAT ISSUE AND, UM, AND ENGAGE ON HOW BEST TO ADDRESS THAT ISSUE AS WELL AS THE TIMING ISSUE THAT NIUS TALKED ABOUT.
NEXT UP, UH, DAVID BLANKENSHIP, UH, YES, THIS IS DAVID BLANKENSHIP WITH CENTERPOINT ENERGY.
UM, I HAVE A COUPLE QUESTIONS HERE.
I'M HOPING YOU CAN HELP ME OUT WITH SOMETHING.
UH, LET'S, LET'S START WITH, UM, DOES ERCOT HAVE A DEF UH, LIKE A DEFINED, UH, IN, IN THE GLOSSARY DEFINITION FOR WHAT THEY MEAN BY BACKUP? 'CAUSE EARLIER THERE WAS SOME LANGUAGE ABOUT DEPLOYING BACKUP RESOURCES, BUT UM, NOT REALLY ANY SPECIFICS ABOUT WHAT THAT MEANT TO DEPLOY THEM.
UM, I THINK BILL KIND OF TALKED ABOUT IT A LITTLE BIT, BUT UH, I'M REALLY KIND OF FOCUSED ON, ARE YOU TALKING ABOUT AN OPEN TRANSITION OR SOMETHING LIKE A CLOSED TRANSITION, BUT FOR LESS THAN I THINK THE PUCT OR NERC DEFINES IT AS LESS THAN A HUNDRED MILLISECONDS.
UM, THAT TYPE OF TRANSITION FOR USE OF BACKUP? UM, YEAH, I MEAN,
I THINK THAT'S BEEN A PRETTY CLEAN AND BRIGHT LINE, UM, TO APPLY.
IF YOU ARE CAPABLE OF OPERATING IN PARALLEL WITH THE GRID AND YOU'RE OVER A MEGAWATT, THEN YOU NEED TO REGISTER WITH ERCOT AND GO THROUGH THE INTERCONNECTION PROCESS AND, AND ALL THAT.
YOU NEED TO HAVE A RESOURCE ENTITY ASSOCIATED WITH THAT.
UM, THAT IS NOT THE KIND OF GENERATION THAT WE READ THE STATUTE 37 0 5 6 1
[01:35:01]
E TO SPEAK OF.UH, WE VIEW THAT AS BEING PURE BACKUP GENERATION THAT NEVER SHOWS UP ON THE GRID.
UM, AND, AND SO, UM, AS WE'RE, UM, CONSTRUING THAT WE'RE ASSUMING THAT THAT GENERATION DOES NOT OPERATE IN PARALLEL WITH THE GRID.
NOW IF THERE'S A, A MORE TECHNICAL NUANCE THERE IN TERMS OF THE TIMING OF THE HANDOFF, UM, THAT'S SOMETHING I'LL NEED ENGINEERS TO OPINE ON.
BUT IN MY GENERAL LAWYER UNDERSTANDING IS THAT THAT IS, UM, THAT GENERATION IS NOT SUPPOSED TO EVER CONNECT TO THE GRID.
AND THAT'S THE POINT OF, OF THIS STATUTE IS IF YOU'RE BACKING UP YOUR LOAD WITH AT LEAST, YOU KNOW, 50% OF YOUR LOAD IS COVERED BY A GENERATION THAT CAN SERVE THAT LOAD, BUT IT'S NOT A GRID FACING GENERATION.
AND THAT'S WHAT TRIGGERS THAT RIGHT OF CURTAILMENT FOR THE ENTIRE AMOUNT OF A LOAD THERE.
BUT I'LL DEFER TO DEON ON SPECIFIC TIMING QUESTION THAT WAS, UH, WAS ASKED ABOUT THERE, DAVID, I WILL ALSO NEED TO DO RESEARCH ON THAT TIMING.
SO I DON'T KNOW THAT I HAVE ANY BETTER ANSWER RIGHT NOW.
UM, WOULD IT BE TOO MUCH TO ASK TO HAVE IT DEFINED IN THE ERCOT GLOSSARY WHAT QUOTE UNQUOTE BACKUP IS BEING INTERPRETED BY THE ERCOT? WE CAN, AND IF I MAY REQUEST I THE TALE OF THIS, UH, PRESENTATION, I'M GONNA, UH, REQUEST, UH, FOR COMMENT.
SO I MAY, UH, REQUEST YOU TO EMAIL ME WHAT DO YOU THINK, UH, WHAT, YOU KNOW, WHAT WERE THE TECHNICAL SPECIFICATIONS THAT YOU WERE, UH, TALKING ABOUT SO WE CAN GO DO SOME RESEARCH ALSO.
I I'LL HAPPY TO SEND THAT TO YOU.
THE, THE TERM AND THE USE OF THE WORD BACKUP TO MEAN EITHER AN OPEN TRANSITION OR A CLOSED TRANSITION OF LESS THAN 100 MILLISECONDS.
UM, IS KIND OF WHAT I WAS THINKING.
UM, HOW IS THE BSCL GOING TO AFFECT ANY KIND OF LOAD SHARE RATIO? OR LET'S SAY WE ARE IN A SITUATION WHERE WE FIND OURSELVES IN EEA THREE, UM, THAT WAS NOT CAUGHT, UM, BY, UH, BY THE PRC, UM, LIKE WE'VE HAD IN THE PAST, UH, LIKE A SLOW FREQUENCY DECLINE DUE TO MAYBE TRAP GENERATION OR, UM, PRE A GENERATION NOT BEING ABLE TO RESPOND FULLY.
UM, ARE, ARE WE GOING TO USE THESE B SCLS TO RESTORE MANUAL LOAD SHED THAT WAS GIVEN UP? UM, WILL WE BE ABLE TO COUNT THESE B SCLS TOWARDS OUR MANUAL LOAD? SHE, UM, NUMBERS IF WE WERE PLANNING ON MAKING THEM AVAILABLE, HOW, HOW DOES ERCOT SEE NAVIGATING THE RELATIONSHIP BETWEEN MANUAL LOAD SHED AND B SCLS IN GENERAL? SO THAT'S, UH, YOU KNOW, I MENTIONED THIS, UH, TO BILL ALSO, IT'S A, IT'S A FAIR QUESTION TO ASK.
UH, WE HAVE CERTAIN OPINIONS, UH, AROUND MANAGING BS SEALS, UH, TO THE EXTENT THAT WE CAN INSTRUCT THEM AHEAD OF AN EEA THREE, WE WERE SUPER COMFORTABLE SAYING, HEY, THEY MAY NOT BELONG IN FIRM LOAD SHARED OBLIGATIONS FOR TSPS.
BUT, BUT IF I'M NOT ABLE TO, THEN THERE IS A FAIR QUESTION TO ASK IS HOW IS, WHAT IS THE BEST WAY TO MANAGE IT IN THE EXAMPLES THAT I CREATED? CERTAINLY IF YOU LOOK AT IT AS BSCL, UH, INSTRUCTIONS BUILD UP, WE ARE ABLE TO PULL BACK ON FIRM LOAD SHED INSTRUCTIONS.
SO THERE IS, UH, YOU, YOU TALKED ABOUT RESTORATION, YOU TALKED ABOUT, UH, YOU KNOW, UH, UH, THERE IS CERTAINLY ONCE WE ARE IN AN EVENT, THE, UH, WE CAN, THERE IS A WAY, A PATHWAY TO BUILDING UP THE SCL CURTAILMENTS AND NOT INSTRUCTING AS MUCH FIRM LOAD SHOULD, DEPENDING ON THE SITUATION.
AND, UH, AND, AND SO THERE IS A HANDOFF THAT IS POSSIBLE, BUT WE, I THINK WE WILL, UH, AS WE TALK ABOUT THE NUANCES, I THINK THESE ARE THE TYPE OF QUESTIONS OR CONVERSATIONS THAT ARE GOOD TO HAVE SO THAT WE CAN ALSO, SO THAT THE POLICY CAN BE DESIGNED APPROPRIATELY.
YEAH, IT SOUNDS LIKE WHERE ERCOT IS GOING TO TREAT THEM SIMILAR TO, UM, LOAD SERVICES, LOAD MANAGEMENT SERVICES, WHERE IDEALLY YOU WOULD CALL ON THEM IN AN EARLIER EEA, BUT IF YOU DON'T GET TO THEM, THEY COULD BE CALLED, YOU KNOW, DURING AN EEA THREE, UH, IF THEY, IF WE JUST SKIP STRAIGHT TO IT.
UM, AND THEN WE KIND OF SORT OUT THE MANUAL LOAD SHED AND RESTORE MAYBE SOME UFLS LOAD IF IT WAS, UH, SHED DURING AN EVENT OR SOME MANUAL LOAD CHAT EVENT AND LET THE MARKET, UH, SERVICES PLAY OUT IN A KIND OF COORDINATED EFFORT.
DO YOU SEE THAT POTENTIALLY GOING, UH, BEING ON THE TABLE FOR DISCUSSION? I THINK WE CAN DISCUSS IT.
SO TWO MORE QUESTIONS, SO WE'LL MOVE ON TO THE NEXT SECTION.
UH, JOEL? YEAH, I, I HAD A COUPLE OF POINTS.
ONE, UM, THIS LENDS ITSELF TO SOME SORT OF MARKET SOLUTION.
[01:40:01]
I MEAN, THE FACT THAT WE'RE TRYING TO DECIDE WHAT ORDER WE'RE GONNA, WE'RE GONNA SHED THESE LOADS IN, THAT BEGS FOR A PRICE WHERE, WHERE THE LOADS CAN THEREFORE SORT THEMSELVES OUT BY HOW MUCH THEY DON'T WANT TO BE CURTAILED IN DOLLARS.AND THEN, UM, THE OTHER, THE OTHER QUESTION IS, YOU KNOW, ON THIS, ON THE LEFT GRAPH, GETTING BACK TO KIND OF NED'S POINT ON THE RIGHT GRAPH, I GUESS WOULD BE MORE APPROPRIATE, GETTING BACK TO NED'S POINT, IT LOOKS LIKE, GIVEN THAT YOU'RE ISSUING BSCL INSTRUCTIONS BEFORE WE GET TO AN EEA TWO, THERE ARE, THERE ARE SERVICES THAT ARE NOT FREQUENCY RESPONSIVE THAT WOULD NOT HAVE BEEN DEPLOYED AND YOU'RE ISSUING ESCL INSTRUCTIONS.
IS THAT CORRECT? IT'S, UH, AGAIN, UH, THERE IS PROBABLY SOME CONVERSATION TO BE HAD AROUND, IF WE, IF WE HAD, IF WE WERE NOT CONSTRAINED BY THE LANGUAGE THAT IS WRITTEN TODAY, HOW SHOULD OPERATING MARGIN BE DETERMINED AHEAD OF, UH, AHEAD OF, UH, BEING IN IT? SO USING FORECASTS, THERE ARE, UH, UH, WHAT I'M TRYING TO GET TO IS IF YOU THINK, UH, THERE ARE WAYS THAT TRIGGERS CAN BE BUILT, WHICH ACCOUNT FOR THAT CAPACITY, WHICH IS BEING PROCURED AS QUOTE UNQUOTE MARKET SERVICES.
SO YOU CAN DO A, HEY, AM I STILL GOING TO BE IN TROUBLE AFTER USING ALL MY MARKET SERVICES? THERE IS A POSTURE LIKE THAT.
I, BUT I THINK, I THINK WHAT YOU DON'T WANT TO DO MM-HMM
SO I'LL PUT IT TO YOU THIS WAY.
AND THIS IS THE TRADE OFF OF LOOKING AT FORECASTS, UH, VERSUS WAITING TILL IT IS TOO LATE.
SO THERE ARE, THERE IS A BALANCE.
I WOULD SAY IF YOU'RE LOOKING AT A FORECAST THAT SAYS YOU NEED B SCLS, YOU SHOULD BE PREEMPTIVELY TRIGGERING THE ERS FOLKS.
I UNDERSTAND YOUR, BECAUSE THEY'RE GETTING PAID FOR THAT, RIGHT? YEAH.
THAT'S ANOTHER WAY TO LOOK AT IT.
SO INSTEAD OF WAITING UNTIL, DO YOU MOVE SOMETHING EARLIER? SO THAT'S AN INTERESTING WAY TO LOOK AT IT.
THERE'S, THERE'S A CONUNDRUM BETWEEN ALL THE LANGUAGE, THE VARIOUS LANGUAGE.
AND THAT'S REALLY WHAT WE'RE TRYING TO POINT OUT HERE IS THAT WHERE THERE, THERE THERE'S ALMOST A NULL SET OF WHAT THE YEAH.
SB SIX LANGUAGE AND THE LANGUAGE IN THE CURRENT PROTOCOLS AS TO HOW WE USE ALL THOSE THINGS.
SO WE'RE GONNA HAVE CHANGE SOMETHING WHICH IS REALLY MISSED.
YEAH, I THINK, I THINK IF YOU DO THE ONE ON THE RIGHT, YOU'RE, YOU'RE CREATING A LARGE DANGER TO BOB'S POINT OF CREATING A PERVERSE INCENTIVE WHERE IT WILL BE A DESIGN CONSIDERATION FOR THE LARGE LOADS OF, WE DON'T WANT TO EXCEED 49% BACKUP GENERATION BECAUSE IT GETS US PUT IN A BUCKET.
WE, WE'D RATHER BE DOWN IN THE FIRM LOADS WITH EVERYBODY ELSE.
WELL, UM,
IT TOOK ME TWO TRIES TO REALIZE BE CHECK WAS TURNING A Q INTO AN A.
UM, AND, AND, AND I HAVE EAR THINGS IN BECAUSE I'M EXPERIMENTING WITH USING 'EM AS HEARING AIDS AND I DIDN'T HEAR EVERYTHING, BUT I THINK I UNDERSTAND WHAT YOUR PROBLEM IS AND, AND I WANT TO AGREE WITH THE LAST SPEAKER THAT ONE OF THE THINGS WE COULD CONSIDER IS MOVING ERS UP.
ERS NOBODY'S FAVORITE SERVICE I KNOW.
BUT, UM, WE DIDN'T, WE DESIGN THAT SORT OF INTERNALLY WITH PROTOCOLS.
THERE WAS SUPPORT FROM THE COMMISSION OR DIRECTION FROM THE COMMISSION IF I REMEMBER TO DEVELOP IT, BUT IT'S NOT CONSTRAINTS.
SO WE COULD ACTUALLY CHANGE WHEN THAT'S CALLED EASIER THAN CHANGING THE LAW.
NOW I EXPECT YOU MAY PURSUE LAW CHANGE AND THAT'S COMING RIGHT UP, SO THAT MIGHT COME IN TIME TO SAVE IT TOO.
BUT I THINK WE COULD TALK ABOUT MOVING
[01:45:01]
ERS TO BE CALLED SOONER AS A WAY TO RESOLVE THIS.THE OTHER IS, I'M WONDERING DOES IT HELP IF, I MEAN YOU HAVE TWO THINGS IN THE LAW.
ONE IS IT ALLOWS YOU ON A FORECAST TO NOTIFY, BUT THEN YOU HAVE TO BE CALLED LATE.
BUT COULD YOU NOTIFY MAYBE A DIFFERENT KIND OF, UM, URGENCIES OR DETERMINATION OR SOMETHING TO, TO SAY, YOU ARE DEFINITELY GONNA BE CALLED TO COME OFF AS SOON AS EEA THREE COMES SO THAT THEY WOULD BE READY AND MAYBE EVEN HAVING TO TAKE ACTION SO THAT THEY COULD COME OFF QUICKER OR SOMETHING.
LIKE MAYBE THERE'S A, A WAY NOT JUST SAYING, OH YOU MIGHT BE CALLED AT AN HOUR, BUT YOU WILL DEFINITELY BE ASKED TO COME OFF WITHIN THE NEXT HOUR OR SO UNLESS SOMETHING CHANGES.
AND SO MAYBE YOU DON'T CALL THEM, BUT IF IT'S ALMOST CERTAIN, MAYBE THAT GIVES OPERATORS A LITTLE BIT MORE, UM, TIME.
OKAY, SO I SAID I WAS GONNA HOLD THE QUEUE.
IS THIS RIGHT IN THE ALLEY WHERE WE STILL ARE? OKAY, IF WE CAN BE BRIEF AND AMAZING, I'LL LET THE LAST TWO SNEAK IN HERE.
UH, SO BILL BARNS, WE'RE GOING TO CLOCK IT.
AND THEN ERIC CONTINUE TO PULL IN THE THREAD OF NON FREQUENCY RESPONSIVE SERVICES.
THE, THE REASON WHY YOU AREN'T SHOWING NONS SPIN AND ECRS IS BECAUSE THE EXPECTATION THOSE WOULD LONG BEEN DEPLOYED WOULD BE MY GUESS.
AND THEN NCLR, WOULDN'T YOU CONSIDER THAT FREQUENCY RESPONSE? THOSE ARE, THOSE ARE UNDER FREQUENCY RELAY.
MAYBE, LET ME PUT IT TO YOU THIS WAY.
BY THE TIME OPERATING RESERVES ARE IN EA TWO PRC OR WHATEVER IS THE MARGIN IS 2,500, THAT PRETTY MUCH MEANS THE ONLY THING I'M SITTING ON IS REGULATION AND SOME AMOUNT OF RRS ON NCL LRS.
SO THAT IS NOW HERE, WHEN YOU SEE NCL GETTING FIRED, IT'S BECAUSE NOW YOU ARE PRINTING 2,500 AND BELOW MARGIN IN REAL TIME.
SO THEY ARE SAYING HOW IS THE MANUAL PART, THIS IS THE MANUAL PART.
THIS IS THE MANUAL I WAS TRYING TO HELP YOU AND NOW YOU MADE IT MORE COMPLICATED.
I'M SORRY,
I WAS, I WAS SAYING THE ONLY THING THAT THAT SEEMS TO BE NON FREQUENCY RESPONSIVE IS ERS.
AND I THINK THERE SEEMS TO BE SOME AGREEMENT WE COULD DEPLOY THAT SOONER, BUT YEAH, IT'S, I GET THE NCLR PROBLEM.
YEAH, IT'S, IT'S, I I I WILL PUT IT TO YOU THIS WAY.
I KNOW THE CONVERSATION HAS GONE, MAYBE YOU CAN DEPLOY ERS EARLIER, I GET IT.
BUT THE WORLD THAT WE ARE HEADING INTO WITH LOTS OF LARGE LOAD THAT MAGNITUDE, HOW MUCH IMPACT WILL IT HAVE? THE, THE POINT HERE THAT WE ARE TRYING TO GET ACROSS IS EVEN WITH DEPLOYING SOME OF THIS EARLIER MARGIN CAN CONTINUE TO DECLINE.
NET LOAD CAN BE HIGHER IN, IN, IN TOWARDS, I MEAN, THOSE EXAMPLES ARE LOADS HIGH WINDSLOW SUNS DECLINING.
AND IN THOSE SITUATIONS, AS WE START DRAINING THE BATTERIES AND WE START GOING DOWN THAT LOW IN OUR RESERVES, WE WILL, THE, THE RISK THAT WE ARE TAKING IS WE WON'T BE ABLE TO PULL OFF AS MUCH BACKUP SUPPORTED CURTAIL LOAD IF WE WAIT FOR MARGINS IN REAL TIME TO BE BELOW 2,500.
AND WE NECESSARILY HAVE TO PULL THE, THE EEA THREE AND START SHEDDING RESIDENTIAL AND OTHER CUSTOMERS AS WE SLOWLY BUILD UP THIS RESPONSE FROM BACKUP SUPPORTED.
I THINK THAT'S THE, THAT'S THE SCENARIO TO KEEP IN MIND IS THIS IS, YOU CAN SLIDE SOME OF THESE RESERVES THAT WE HAVE OUT, BUT ULTIMATELY THAT IS THE DAY AND THAT IS THE SITUATION.
AND IN THAT SITUATION, THIS IS POTENTIALLY HOW MAYBE OUT, I, I THINK THERE'S AN ARGUMENT TO BE MADE THAT THE ONLY ISSUE WE HAVE HERE IS WITH THE RS.
'CAUSE EVEN FOR MANUAL, UH, NRS, YOU DEPLOY THOSE WHEN YOU BASICALLY CAN'T HOLD RESERVES AT 25.
THAT'S WHAT I WOULD CON I THINK THERE'S A REASONABLE INTERPRETATION THAT'S STILL FREQUENCY RESPONSIVE, BUT I DON'T WANNA OVERCOMPLICATE THIS.
UH, ERIC, LAST QUESTION THEN WE'RE GONNA MOVE ON TO THE LAST SET OF SLIDES.
GIVEN THE FACT, UH, TWO THINGS.
ONE IS THAT WE HAVE EASY ENTRY OF NEW RESOURCES YEAR AFTER YEAR.
SO WHEN, WHEN THERE APPEARS TO BE A NEED, WE'LL SEE MORE STORAGE OR SOLAR, WHATEVER.
AND SECONDLY THAT THE WORST RELIABILITY PROBLEMS WE'RE GONNA BE FACING PRETTY MUCH NOW, GIVEN THE, SO SOLAR AND STORAGE COMBINATION IS GOING TO BE A COLD WINDLESS WINTER NIGHT DURING LIKE A WINTER STORM.
URI, I JUST WANNA MAKE SURE I'M
[01:50:01]
UNDERSTANDING THIS CORRECTLY.IS THERE, ARE THERE PROVISIONS THAT GIVEN A WEATHER FRONT COMING IN THAT ERCOT COULD CALL MORE OF THESE BACKUP SERVICES, PROCURE MORE? SO YOU, AS SOMEONE SAID, USE PRICE AND WILLINGNESS TO PAY TO LINE UP MORE RESOURCES.
SO YOU GET FOLKS WHO RAISE THEIR HAND TO SAY, YES, WE CAN DO IT, AND THEREFORE REDUCE THE AMOUNT OF FORCED, UH, CURTAILMENTS, THANK YOU.
REMEMBER THERE'S ONE OF THE THINGS WE'RE NOT TALKING ABOUT TODAY, IT WAS ON NIKO'S LIST, WHICH IS THAT, UH, THE DEMAND LARGELY DEMANDERS MANAGEMENT PROGRAM, WHICH WE'VE TALKING ABOUT IN OTHER, UH, VENUES.
AND SO, YOU KNOW, TO SOME EXTENT THAT WOULD BE THE PLACE FOR THAT KIND OF THING, I THINK.
SO THEN YOU'RE TALKING ABOUT SITUATIONS HERE THAT ARE HOPEFULLY, UM, BOTH BY PLANNING AND BY SOMEWHAT LUCK ARE GONNA BE EXTREMELY RARE.
WE HOPE THAT ENOUGH RESOURCES GET BUILT THAT THEY'RE, UH, EXTREMELY AWARE.
ALRIGHT, SO WE'RE GONNA GIVE TIKA THE FLOOR TO FINISH OUT HER SLIDE.
SHE TELLS A DOZEN TO GO AND WE HAVE 40 MINUTES LEFT AND WE'LL OPEN UP FOR QUESTIONS.
ALRIGHT, SO THIS PARTICULAR SECTION NOW, UH, TAKES A TURN ON THAT VISIBILITY ANGLE THAT WE TALKED ABOUT AND WE TALK ABOUT, WELL, WHAT IF THERE WERE REQUIREMENTS TO REGISTER, GIVE VISIBILITY, AND HAVE COMPLIANCE? HOW COULD THAT SITUATION THAT WE SAW EVOLVE? SO NOW I LAID OUT, AS WE STARTED THIS CONVERSATION AROUND BACKUP SUPPORTED GUT LEVEL LOADS THAT REALLY THERE ARE THREE THINGS WE NEED.
I WILL NOT REPEAT WHAT THOSE THREE THINGS WERE, BUT TO GET TO MEET THOSE THREE THINGS, KNOWING WHERE EACH BACKUP SUPPORTED CURTAIL LEVEL LOADS, WHERE EACH NET METER CURTAIL LEVEL LOAD, IT'S WHAT IS THEIR CURTAILMENT CAPABILITY, THE IDEA OF BLOCKS VERSUS FULL, WHAT IS THEIR REAL TIME CONSUMPTION? THEN ENSURING THAT EACH IS OBLIGATED TO RESPOND WHEN INSTRUCTED WITHIN A SET CODE, A RESPONSE TIME WILL HELP.
SO THERE ARE REALLY THREE TYPES OF, UH, REQUIREMENTS THAT CAN POTENTIALLY BE THOUGHT ABOUT HERE.
ONE IS REGISTER AND PROVIDE VISIBILITY ON LARGE LOADS.
SO THIS WOULD ALLOW US TO GATHER EXACTLY THAT.
WHERE ARE THESE LOADS? WHAT IS THEIR CAPABILITY? WHAT ARE THEY DOING IN REAL TIME? ESTABLISH REQUIREMENTS THAT IN REQUIRE THESE RESOURCES TO RESPOND WHEN THEY ARE INSTRUCTED AND SET A CLEAR CURTAILMENT RESPONSE TIME.
I THINK THERE WAS A, THERE WAS A FEW POINTS RAISED AROUND HOW YOU CAN ESTABLISH THOSE, BUT LET'S, UH, LET'S ASSUME WE CAN ESTABLISH THOSE, THESE IN OUR MINDS WOULD HELP US ADDRESS SOME OF THE POINTS THAT WE MADE A WHILE AGO, HAVE A CLEAR RESPONSE TIME BECAUSE THERE IS NOW COMPLIANCE, THERE'S VISIBILITY AND THERE IS COMPLIANCE REQUIREMENTS.
WE SHOULD BE ABLE TO SIZE OUR INSTRUCTIONS AND ENSURE THAT THEY ARE, UH, WE GET THEM.
IT MAY NOT CHANGE THE TWO ITEMS WITHIN PURA ITSELF.
SO WHICH IS WHEN THE INSTRUCTIONS TO CURTAILMENT MAY BE ISSUED AND TO WHO.
UH, SO HOW WILL SOMETHING LIKE THIS PLAY OUT IS REALLY THE, UH, SET OF NEXT SLIDES THAT COME IN AND TALK ABOUT.
SO WHAT WOULD, WHAT COULD POTENTIALLY ROLES AND RESPONSIBILITIES LOOK LIKE UNDER THESE NEW REQUIREMENTS? EACH LARGE NODE WOULD BE ADDED INTO OUR NETWORK MODEL OR INTO OUR MODEL.
THERE WOULD BE DEFINED ROLES ON WHO PROVIDES SITE DATA, WHO PROVIDES REAL TIME TELEMETRY AND WHERE APPLICABLE WHO ACTS ON CURTAILMENT INSTRUCTION SENT.
NOW, UH, THIS GRAPHIC HERE AGAIN, ATTEMPTS TO EMPHASIZE, UH, THOSE POINTS OF WHAT, WHAT WOULD BE IN OUR NETWORK MODEL, WHAT WOULD GIVE, WHAT WOULD BE IN OUR VISIBILITY, WHO WOULD BE, UH, PROVIDING THE DATA TO US.
AND THERE WAS A, UH, THE IDEA OF A LARGE LOAD ENTITY THAT'S AN OWNER WHO WOULD BE REQUIRED TO PROVIDE THE SITE DATA TO US WHEN IT COMES TO REAL TIME CONSUMPTION.
I, I'VE PUT IN ASTERISK HERE AND WE'LL TALK ABOUT WHY THAT ASTERISK EXISTS.
NOW, THERE IS ONE MORE IDEA WITHIN THIS.
FOR THOSE LARGE LOADS WHO FALL UNDER THE TWO SB SIX BUCKETS WE'VE BEEN TALKING ABOUT BACKUP SUPPORTED CURTAIL LEVEL AND NET METER CURTAIL LEVEL.
ALSO, THE REQUIREMENTS FOR THESE ARE ALREADY IN THE PROTOCOLS TODAY.
WE WOULD ALSO HAVE AN ADDITIONAL REQUIREMENT FOR A QSE.
[01:55:01]
THIS QSE WOULD, UH, SERVE AS AN OPERATOR FOR THAT LARGE LOAD.HE WOULD BE RESPONSIBLE FOR PROVIDING TELEMETRY 24 7 COMMUNICATION, AND HE WOULD BE THE ENTITY WITH OBLIGATION FOR CURTAILMENT.
SO ONCE AN INSTRUCTION IS ISSUED AND REACHES THE, THE LARGE LOAD, IT WOULD BE THE, UH, THIS ENTITY WHO WOULD BE RESPONSIBLE ALSO FOR INSURING TOO THAT THE LARGE LOAD ACTS ON THAT CURTAILMENT.
SO THOSE ASPECTS THAT I MENTIONED AROUND REAL TIME CONSUMPTION.
SO FOR ANY LARGE LOAD THAT DOESN'T FALL IN THESE THREE BUCKETS, WE WOULD, UH, WE WOULD WANT, WE WOULD STILL NEED EYES ON THOSE LARGE LOADS AND WE WOULD RELY ON THE TSPS TO PROVIDE THAT, THOSE EYES TO US.
AND THIS WOULD AGAIN, BE FOR REAL TIME SITUATIONAL AWARENESS.
AND WHEN IT COMES TO BACKUP SUPPORTED CURTAIL LOADS, UH, I DID, UH, IDENTIFY HERE IT WOULD LIKELY APPLY, OR ONE POTENTIAL WAY TO DO IS, IS TO APPLY TO ANY BSC THAT INTERCONNECTS INTO OUR CARD SYSTEM AFTER JUNE 20TH, 2025.
BUT THIS COULD POTENTIALLY BE THE LAYOUT OF WHAT THAT, UH, OF WHAT THE ROLES AND RESPONSIBILITIES WOULD LOOK LIKE UNDER THOSE REQUIREMENTS.
SO IF THIS EXISTED, HOW COULD THAT ILLUSTRATIVE EXAMPLE EVOLVE THIS SLIDE ATTEMPTS TO GET TO IT? I SLID IN A, A, A A THIRD SCENARIO HERE IN THE MIDDLE.
AND WHAT THIS SAYS IS, HEY, UH, IF I HAVE ALL OF THESE REQUIREMENTS WITHIN THE PROTOCOLS, I'M STILL BOUND TO CURTAIL THESE BACKUP SUPPORTED LOADS BASED OFF OF REAL TIME THRESHOLDS OF OPERATING MARGINS.
BUT NOW I HAVE THIS IDEA OF REGISTRATION AND COMPLIANCE.
HOW WOULD THE SITUATION EVOLVE? NOW, YOU, UH, AND I, I'VE KEPT THE EX TWO CASES THAT WE HAVE BEEN LOOKING AT IN SLIDE 19 ALSO HERE ON THE SITES.
WHEN, WHEN WE ARE IN A WORLD WHERE REGISTRATION EXISTS AS FAR AS RESPONSE FROM THE BACKUP SUPPORTED CURTAIL LOAD GOES, OUR CART CLEARLY IS SIZING IT BASED OFF OF THE LOAD'S CAPABILITY AND THE SYSTEM NEEDS.
THE INSTRUCTIONS THAT I SEND AND THE RESPONSE THAT I GET LOOKS VERY SIMILAR TO THE, UH, THE, THE SCENARIO I HAD BEEN SHARING WHERE I HAD NEAR TERM, WHERE THE INSTRUCTIONS WERE SENT BASED OFF NEAR TERM FORECAST, BUT I HAD VISIBILITY.
SO THE RESPONSE YOU WILL NOTICE, UH, KEEPS, TENDS TO FOLLOW.
THE ONLY DIFFERENCE IS I CAN'T START IT AHEAD OF AN EEA, I CAN'T START IT BASED OFF OF NEAR TERM FOCUS.
I'M STARTING IT WHEN REAL TIME MARGIN FALLS BELOW 2,500.
SO WHAT IS THE DIFFERENCE NOW, IF YOU COMPARE IT TO THE, UH, TO THE REAL TIME THRESHOLD WITHOUT REGISTRATION SCENARIO? THE VOLUME OF FIRM LOAD SHED DOES REDUCE BECAUSE I'M, I HAVE, UH, ABILITY TO ASK FOR EXACTLY WHAT THE SYSTEM NEEDS AND THE RULES THAT WE'VE JUST TALKED ABOUT.
BUT I STILL HIT FIRM LOAD SHED BECAUSE AGAIN, UH, THE INSTRUCTIONS ARE STARTING LATE AS FAR AS, UH, UH, UH, UH, THE, UH, AS FAR AS THE INSTRUCTION PATTERN GOES.
SO, SO THE FIRM LOAD, SHED STILL LOCKERS.
THE VOLUME ISN'T, THAT MAY NOT BE AS HIGH, BUT THE FIRM LOAD, SHED STILL HACKERS TILL MATERIAL RESPONSE FROM BACKUP SUPPORTED LOAD BUILDS UP.
AND AS AS IT BUILDS UP, WE ARE ABLE TO PULL BACK.
UM, SO THAT'S WHAT THIS, THAT'S POTENTIAL OF HOW THE, UH, THE SITUATION COULD PLAY OUT IF WE WERE TO LIVE WITHIN THE BOUNDARIES THAT SB SIX HAS ESTABLISHED AS FAR AS CURTAILING THIS LANDLORD GOES.
SO THERE WAS SOME CHANGE IN THE OUTCOME BY HAVING THOSE, UH, THOSE REVISIONS AROUND REGISTERING VISIBILITY AND COMPLIANCE, BUT IT DID, THEY WEREN'T ENOUGH TO CHANGE THE TIMING CONDITION THAT IS WITHIN SP SIX AND OF COURSE, THE UTILITY PATH ALSO, WE WILL CONTINUE TO HIGHLIGHT IT.
IT DOES BRING RISKS OF DELAYS AND MISCOMMUNICATIONS.
WE HAVEN'T REALLY MODELED THOSE, BUT THEY CONTINUE TO BE LIMITATIONS THAT ARE WORTH BEING AWARE OF.
UH, AND SO PROTOCOL CHANGES CAN ADDRESS SOME PORTIONS OF THE REQUIREMENTS, UH, ULTIMATELY FOR THE DESIGN OF, UH, CURTAILMENT OF BACKUP SUPPORTED LOADS.
BUT THEY MAY, UH, STILL INHIBIT, UH, CART'S ABILITY TO USE BCLS TO AVOID CURTAILMENT OF FIRM LOAD SHED.
SO FROM HERE, I'LL TRANSITION OVER.
THERE'S A COUPLE MORE SLIDES LEFT.
UH, AND THIS PARTICULAR SLIDE IS MORE OF A, YOU MAY ALL BE AWARE THAT NERC IS ALSO ACTIVELY
[02:00:01]
WORKING ON STANDARDS THAT APPLY TO COMPUTATIONAL LOADS.THERE IS, UH, A SERIES OF REQUIREMENTS OR STANDARDS THAT THEY HAVE PUT OUT UNDER PROJECT 26 0 2, UH, WHERE, WHICH APPLY TO COMPUTATIONAL LOADS SIZED 50 MEGAWATTS OR MORE.
THEY CREATE CONSTRUCTS WHERE BAS WHERE ARE EXPECTED TO INTERACT DIRECTLY WITH THE CUSTOMER THROUGH A LOAD OWNER AND A LOAD OPERATOR, A COMPUTATIONAL LOAD OWNER AND A COMPUTATIONAL LOAD OPERATOR.
THEY HAD A BALLOT THAT, UH, A DRAFT BALLOT THAT PASSED THAT'S THEIR FINAL BALLOT IS EXPECTED TO GO OUT, UH, THIS MONTH.
AND, UH, NER IS EXPECTED TO GO THROUGH ITS BOARD APPROVAL AND FERC PROCESS BY DECEMBER END OF, UH, END OF THIS YEAR.
SO NOW, IF, UH, FERC WERE TO APPROVE THESE STANDARDS THAT NERC IS WORKING ON, I MEAN, IT UH, GOES BEYOND SAYING ERCOT WILL NEED PROTOCOL REVISIONS TO MEET NERC REQUIREMENTS.
NOW, SPECIFICALLY, ONE THING THAT I DO WANT TO TALK ABOUT IS WHAT IS THE IMPLICATION? WHAT IS THE POTENTIAL IMPLICATION OF THOSE REQUIREMENTS? SO IF NERC WERE TO APPROVE THE COMPUTATIONAL, UH, THOSE STANDARDS, COMPUTATIONAL LOAD SITES WOULD REQUIRE TO HAVE AN, WOULD BE REQUIRED TO HAVE AN OPERATOR WHO IS RESPONSIBLE FOR TELEMETRY AND COMMUNICATIONS WITH THE BA.
SO AS WE THINK ABOUT PROTOCOL REVISIONS FOR
SO THAT'S, UH, REALLY I'VE GRADED OUT EVERYTHING ELSE, AND I'VE SAID SOMETHING ELSE WE CAN DO IN THAT ARROW PATH WHERE WE SAY A QSC IS NEEDED, THAT QSC REQUIREMENT COULD ALSO BE EXTENDED TO APPLY TO ALL LCLS.
NOW EXTENDING THIS REQUIREMENT TO ALL SCLS ABOVE 50 MEGAWATTS WOULD LET ONE SET OF PROTOCOL REVISIONS MEET BOTH SB SIX CURTAILMENT NEEDS AND WHAT NERC IS PROPOSING AS REQUIREMENTS.
SO THAT IS SOMETHING ELSE, UH, FOR EVERYONE TO CONSIDER, UH, IN CONTEXT OF WHAT POTENTIAL IMPROVEMENT CHANGES CAN BE MADE TO THE PROTOCOLS.
NOW WHAT I'LL DO IS, I'M GONNA KEEP GOING.
THIS HAS ABOUT THREE SLIDES LEFT.
UH, AND REALLY THE GOAL OF THIS PARTICULAR SECTION IS TO PLANT A SEED FOR THE NEXT SET OF WORKSHOPS.
THERE WERE QUITE A FEW CONVERSATIONS TODAY THAT TRIED TO GET INTO THE HOW, HEY, HOW WILL YOU DO X, Y, AND Z? SO THERE IN OUR MINDS ALSO, AS DAN MENTIONED, AS WE'VE STARTED THINKING ABOUT THIS AND STARTING TO DRAFTING REQUIREMENTS, THERE WERE SEVERAL ELEMENTS WHERE WE, WE SEE THE NEED FOR INPUT AND, UH, AND UNDERSTANDING OF, UH, FROM STAKEHOLDERS.
SO I, WE ALSO EARMARK CERTAIN, UH, TOPICS AS, I'M NOT GONNA GET INTO THESE TOPICS TODAY.
THERE ARE TWO TOP, THERE ARE TWO ITEMS THAT I DO WANT TO TOUCH, BUT THERE ARE SEVERAL OTHERS THAT HAVE LISTED HERE, WHICH, UH, AS WE START GETTING INTO THE HOW WILL BE VALUE WILL BE THINGS THAT WE WILL BRING FORTH TO AT LEAST START THE DISCUSSION AND START TALKING ABOUT OPTIONS.
UH, AND SO, SO LET'S, SO WHAT I'M GONNA DO IS I'LL QUICKLY GO THROUGH THOSE TWO ITEMS THAT ARE WORTH THINKING ABOUT RIGHT NOW.
UH, SO THE, THE POINT, SO TODAY THE V-N-P-R-R 1238 WAS WRITTEN, IT CONTEMPLATED CURTAILING VECL LOAD WHEN MARGIN OR PRC FALLS BELOW 3,100.
UH, AS WE START THINKING ABOUT SB SIX LOADS, NET METER CURTAIL LEVEL LOADS, AND EVENTUALLY BACKUP SUPPORTED, THERE IS THE WAVE COMMISSION REQUIREMENTS FOR NET METER IS WRITTEN.
WE ARE, WE HAVE THE ABILITY TO INSTRUCT CURTAILMENT OF THESE LOADS IN ANTICIPATION OF AN EMERGENCY AHEAD, UH, TO AVOID AN EMERGENCY.
SO IT'S, UH, SO IT'S POSSIBLE THAT WE INSTRUCT AN MCL LOADS TO CURTAIL BEFORE PRC OR ACTUAL RESERVES FALL BELOW, UH, THE 3,100 THRESHOLD.
IN THAT SITUATION, WE DO THINK THE INTENTION OF THE 1238 LANGUAGE WAS TO, UH, WAS FOR THESE VECL LOADS TO BE DEPLOYED EARLIER AND TO ACHIEVE
[02:05:01]
IT.WHAT WE, UH, THE QUESTION THAT COMES TO OUR MIND IS, SHOULD VEHICLES BE DEPLOYABLE BASED OFF OF NEAR TERM FORECASTS AS WELL, JUST LIKE N MCLS ARE.
SO WE CAN LINE THEM THEIR CURTAILMENT UP AHEAD OF NET METER AT CURTAIL LEVEL LOADS.
SO AGAIN, UH, SO THAT'S THE FIRST QUESTION, UH, TO PLANT A SEED AS FAR AS, UH, WHAT, UH, WHAT, WHAT, UH, WHAT STAKEHOLDERS HERE THINK IS THE RIGHT APPROACH OR WHAT WOULD BE THE RIGHT INTENTION IN OUR MINDS? THE I MY T'S THINKING AT LEAST IS IT MAKES SENSE THAT VEHICLE DEPLOYMENT SHOULD BE NOT JUST BASED OFF OF WHEN PRC IS BELOW, BUT WHEN NEAR TERM FORECASTS INDICATE PRC MAY BELOW THE SECOND ITEM WAS SOMETHING AS WELL THAT I WAS MENTIONING AS, UH, UH, AS FOLKS STARTED THINKING AHEAD, HOW DO SB SIX LOADS PLAY WITHIN THE TSP LOAD SHE OBLIGATION.
AND THAT'S EXACTLY A QUESTION IN OUR MINDS.
ALSO, WHEN WE WERE GOING THROUGH THE NET METERING PROCEEDINGS, I THINK THE, UH, COMMISSION DID, UH, INSTRUCT US TO, UH, UH, TO TAKE THESE NET METER CURTAIL LEVEL LOADS OUT FROM THE TSP LOAD SHED PLAN.
AND, AND BECAUSE THESE LOADS CAN BE CURTAILED AHEAD OF ANY EEA THREE THAT MAKES, UH, I THINK WE UNDERSTAND AND WE AGREE FOR BACKUP SUPPORTED CURTAIL LEVEL LOAD, THE QUESTION IS OPEN.
I MEAN, TODAY, AT LEAST, UH, IF WE WORK WITHIN THE BOUNDARIES THAT HAVE BEEN SET BY SB SIX, THESE LOADS MAY NOT BE CURTAILED BEFORE AN EE THREE.
SO WHAT IS THE, SO HOW SHOULD THESE BE HANDLED, UH, IS AN OPEN QUESTION, AT LEAST AS FAR AS TSP LOAD SHED OBLIGATIONS AND, UH, THE IMPACT OF THESE LOADS ARE CONCERNED.
UH, SO THIS IS ANOTHER TOPIC, UH, THAT IS GOOD, UH, IS GOOD TO, UH, POSE OUT TO THE AUDIENCE AND, AND SEE WHAT RESPONSES, UH, OR WHAT, UH, THOUGHTS.
IT MAY, THEY MAY, YOU MAY, UH, YOU MAY, UH, YOU MAY HAVE ON IT.
YOU, UM, TO THE EXTENT YOU HAVE A RESPONSE NOW, UH, HERE AT THE TAIL, UH, OF THE CO OF THE CONVERSATION, PLEASE DO SHARE.
OTHERWISE, WHAT I'M GONNA DO IS I'M QUICKLY GONNA TELL YOU WHAT WE ARE THINKING.
WE'VE REALLY APPRECIATED ALL THE INSIGHTS, UH, THAT WE'VE GOT TODAY.
IF YOU HAVE FEEDBACK FOR US, PLEASE, SPECIFICALLY ON THESE POTENTIAL, UH, PROTOCOL REVISIONS OR ANYTHING ELSE WE'VE DISCUSSED TODAY, PLEASE, UH, PLEASE CONSIDER SENDING THEM OVER, UH, TO US BY THE END OF, BY END OF OCTOBER NINE THIRD.
WE DO HAVE A FOLLOW UP WORKSHOP SCHEDULED FOR NOVEMBER 6TH.
SO WE WILL LOOK TO USE YOUR FEEDBACK AND DRAFT THE NEXT SET OF CONTENT.
SO IT'LL, IT'LL BE VERY HELPFUL AS FAR AS WHO TO SEND, UH, FEEDBACK TO.
YOU CAN SEND IT DIRECTLY TO ME.
UH, AND I CAN, I WILL REVISE THE SLIDE DECK AND PUT MY EMAIL ADDRESS AND, UH, THE, THE NOVEMBER 6TH DATE HERE AS WELL.
UM, AND THIS IS MY LAST SLIDE, SO I'LL PAUSE RIGHT HERE.
I KNOW THERE WAS SOME, SOME THOUGHTS, SO LET'S, LET'S GET TO THEM.
CAMERON WITH THE DATA CENTER COALITION.
UNDER THE OTHER CONSIDERATION SLIDE, I THINK ONE THING THAT, THAT, UM, SHOULD BE A PART OF THIS DISCUSSION IS TAKING INTO ACCOUNT, UH, AIR EMISSIONS REQUIREMENTS ON THE FEDERAL AND STATE LEVEL.
UM, AS, AS LAW IS CURRENTLY WRITTEN, UM, THE EPA AND TCQ HAVE, UH, CAPS ON THE NUMBER OF HOURS YOU CAN USE, UH, BACKUP GENERATION, PARTICULARLY IN DURING A NON-EMERGENCY.
AND SO IF THESE MANDATORY CURTAILMENTS, UM, ULTIMATELY, UH, REQUIRE A FACILITY TO SHIFT FROM THEIR TRADITIONAL POWER SOURCE TO THEIR BACKUP GENERATION, UM, WHERE THEY, WE TYPICALLY USE, AND OUR MEMBERS TYPICALLY USE TIER TWO OR TIER FOUR, UH, DIESEL EMERGENCY GENERATORS, UM, THEY COULD BE RUNNING AGAINST, UH, THOSE CAPS THAT THEY'VE BEEN, UH, ALLOCATED FOR, FOR NON-EMERGENCY.
UM, ANOTHER PIECE OF THIS THAT I THINK, UM, IS IMPORTANT TO, TO, TO NOTE IS THAT NOT ALL DATA CENTERS HAVE FULL BACKUP GENERATION ON SITE.
AND SO TAKING THEM INTO ACCOUNT WHEN PLANNING, UH, IS, IS IMPORTANT.
ULTIMATELY, RIGHT NOW, TCEQ HAS A BROADER, UM, DEFINITION OF, OF, OF WHAT CONSTITUTES AN EMERGENCY RUN HERE IN THE STATE THAN, THAN THE EPA DOES.
AND SO I REC, I RECOGNIZE THAT I'M TALKING TO A ROOM FULL OF ENERGY EXPERTS ON HOW TO TACKLE AIR EMISSIONS ISSUES, BUT I THINK THEY, THEY WORK HAND IN HAND, PARTICULARLY WHEN, WHEN
[02:10:01]
IT'S A REQUIREMENT AND ULTIMATELY THEY, THAT COMPANIES HAVE TO RUN INTO THAT.SO A COUPLE THINGS THAT, THAT I THINK WOULD BE BENEFICIAL, AND I DON'T WANNA MONOPOLIZE THE TIME IS, IS WORKING WITH EPA AS WE ARE, AND TCQ, UM, WHO, WHO HAVE BEEN VERY HELPFUL, BUT TO, TO REFINE WHAT, WHAT EXACTLY CONSTITUTES AN EMERGENCY AND THEN PROVIDE SOME SORT OF PATHWAY, UM, FOR, FOR THOSE WITHOUT FULL BACKUP, UH, GENERATION, UH, CAPACITY TO MEET THE REQUIREMENTS HERE, UM, ARE ARE SOME SORT OF, UM, FOCUS ON, ON THOSE WITH, WITH, WITH THE ABILITY TO, TO CURTAIL A LITTLE BIT EASIER.
AND SO, I KNOW THAT WAS LONG-WINDED.
I JUST THINK IT'S AN IMPORTANT COMPONENT HERE.
UH, BRIAN SAMS, UM, SB SIX IS KIND OF LITTERED WITH LANGUAGE THAT REQUIRES ERCOT TO INCLUDE DEPLOYMENTS FOR RELIABILITY AS, UH, LOAD AS FIRM LOAD SHED AND INCLUDE THAT IN PRICE ADJUSTMENTS.
AND MAYBE THAT'S A SUB BULLET UNDER RECALL AND RESTORATION.
I JUST, UH, WANNA MAKE SURE THAT, YEAH, THAT WE'RE, UH, ESPECIALLY ACCOUNTING FOR, FOR THAT IN PRICE FORMATION PRIOR TO WHEN WE HIT EEA.
I MEAN, PROBABLY IN THE EA TWO THREE, IT DOESN'T MATTER 'CAUSE WE'LL BE AT THE CAP, BUT THERE'S STRONG INCENTIVES, UH, FOR, FOR CURTAILMENT IF WE HAVE THE PRICE RIGHT PRIOR TO EEA.
AND SO, UH, JUST IT, IT NEEDS TO BE SOMETHING THAT IS EMPHASIZED AND DONE AT THE SAME TIME AS, UH, ANY OF THESE OTHER, UH, UM, YOU KNOW, COMPONENTS OF THE RULE.
UH, AND I, I DON'T WANT TO BE IN A PLACE WHERE, UM, PART OF THE ROLE IS IMPLEMENTED, BUT THAT PART ISN'T IMPLEMENTED AND, UH, JUST WANNA FLAG THAT, THAT'S A EXTREMELY IMPORTANT PART.
UM, I ABSOLUTELY AGREE WITH YOU.
PART OF THE, I HAVE BEEN PUSHING TO HAVE THIS WORKSHOP FOR A WHILE NOW TO MAKE SURE THAT THE MARKET AS A WHOLE UNDERSTANDS WHAT THE RULES OF THE ROAD ARE GONNA BE, HOW IT'S GONNA HAPPEN, HOW MUCH OF THE TIME WE MAY HAVE TO BE IN THIS KIND OF SITUATION OR NOT, AND THOSE KIND OF THINGS.
I MEAN, I DID A PRESENTATION AT THE BC A LONG TIME AGO ABOUT THAT.
AND PART AND PARCEL OF THAT IS FOR THEM TO UNDERSTAND THE PRICING IMPACTS OF IT.
'CAUSE ONCE YOU UNDERSTAND WHAT THE RULES OF THE ROAD ARE AND THE PRICING IMPACTS, AND I'M PREACHING TO THE CHOIR, TO CAMERON
AND THEN MAYBE WE WILL BE IN THIS SITUATION LESS OFTEN EVENTUALLY.
NOW, I SAID A WHILE AGO, I HOPE THIS NEVER HAPPENS, BUT YOU KNOW, IN THE NEXT FEW YEARS IF THE LOAD BUILDS OUT FASTER THAN THE GENERATION BUILDS OUT, THEN WE COULD BE USING THIS MORE OFTEN.
SO I JUST THINK THAT'S A CAVEAT TO REMIND PEOPLE OF.
BUT, BUT I AGREE WITH YOU ABOUT THE PRICING IMPACTS.
WE'LL ABSOLUTELY BE COVERING THAT AT THE SAME TIME.
IT'LL BE PART AND PARCEL OF WHATEVER NPR WE PUT OUT.
OKAY, THREE, THREE QUICK THINGS.
ONE, CAMERON MAKES AN EXCELLENT POINT ON BACKUP GENERATION AND AIR PERMITS.
WE REALLY NEED TO THINK ABOUT HOW THAT FITS IN ON, UM, PURA NOT, YOU KNOW, HAVING THE UTILITIES EMBEDDED IN THIS CONVERSATION.
I'M SURE ERCOT LEGAL OR THE PUC WOULD BE HAPPY TO TAKE THIS WHEREVER IT NEEDS TO GO.
SAY, WE NEED THIS CHANGED SO WE CAN SHED DATA CENTERS RATHER THAN IN RESIDENTIAL CUSTOMERS.
I THINK THAT'S GONNA TAKE ABOUT THREE MINUTES TO GET APPROVED.
AND THEN LASTLY ON NPR 1238, THE VOLUNTARY EARLY LOAD CURTAILMENT.
I WANNA REMIND EVERYONE WHY WE DID THAT.
WE DID THAT TO ALLOW THE LOADS TO CURTAIL EARLY.
WE WERE FORCING THE LOADS TO STAY ONLINE AND CONSUME WHEN FUNCTIONING PROPERLY.
ERCOT SHOULD NEVER GET A RESPONSE FROM THE VOLUNTARY EARLY CURTAILMENT LOAD.
IT WAS A GUARANTEE THAT ERCOT COULD PUSH THE BUTTON IF SOMEBODY SCREWED UP.
BUT THESE WERE LOADS THAT WANTED TO CURTAIL AT A HUNDRED DOLLARS.
THEY SHOULD NEVER, ERCOT, SHOULD NEVER NEED TO PUSH THAT BUTTON.
THOSE LOADS ARE SUPPOSED TO BE GONE BEFORE WE EVER GET THERE.
SO I DON'T THINK THERE'S A PROBLEM WHEREVER WE WANT TO SET THE CURTAILMENT FOR THOSE GUYS.
[02:15:01]
ERCOT SHOULD REALLY GET NOTHING WHEN THEY PUSH THAT BUTTON.WELL, I WAS GONNA MAKE THE SAME POINT BOB JUST MADE ABOUT THE, THE VELES THAT THEY SHOULD BE OFF EARLY AND UH, I'LL JUST SUPPLEMENT WITH IT THAT SOME WILL ALSO BE B SCLS AND POSSIBLY EVEN NCLS.
AND SO IN THAT CASE, YOU KNOW, YOU DON'T NEED TO, YOU KNOW, DOUBLE TAP THEM WITH THE SAME OBLIGATION.
IN ADDITION TO ALL THE REASONS BOB JUST SAID.
UM, ON TOPIC TWO, I JUST WANTED TO GIVE SOME, UH, SHOOTING FROM THE HIP FEEDBACK.
I THINK ERCOT, YOU'VE GOT IT ABSOLUTELY RIGHT FOR THE NCLS, AND I THINK THE SAME SHOULD APPLY FOR THE B SCLS AS WELL.
UM, SENATE BILL SIX DID, DID ONE THING, AND THAT WAS IT.
IT PUSHED SOME OF THESE LARGE LOAD CURTAILMENT OBLIGATIONS REALLY TO AN, TO AN ERCOT DIRECTIVE, UM, WHERE ERCOT IS, YOU KNOW, MANAGING THAT, UM, DIRECTLY.
AND THEN YOU ALSO HAVE SOME SCENARIOS WHERE YOU HAVE THE COMMISSION, UM, YOU KNOW, DIRECTING IT AND IT'S FLOWING THROUGH, UH, QUEASY TO, TO MANAGE IT.
SO, UM, I THINK Y'ALL HAVE THE, THE RIGHT THINGS THERE.
UM, JUST GENERALLY, UH, APPRECIATE Y'ALL PUTTING ON THIS WORKSHOP AND, AND TAKING THE TIME TO WALK US THROUGH.
I KNOW WE'VE, WE'VE ALL GOT A LOT OF THOUGHTS AND FEEDBACK FOR YOU.
UM, AND, AND DAN, I I, I ALSO HOPE WE DON'T HAVE TO USE THIS AND GIVEN HOW MUCH, UH, EXCESS CAPACITY WE HAVE ON THE SYSTEM RIGHT NOW AS WE BROKE THROUGH OUR, UH, OUR PEAK LOAD RECORD THIS SUMMER, UM, HOPEFULLY WE WON'T EVEN NEED TO USE THIS IN THE NEXT FEW YEARS.
ALRIGHT, THINK YOU DID BILL BARNES, JUST CLARIFYING SLIDE 33.
IT SOUNDS LIKE, UM, YOU JUST WANNA BE SURE THAT THESE ARE TREATED SIMILAR TO, UH, V ECLS WHERE THEY WERE REMOVED FROM THE LOAD SHED OBLIGATION BASED ON HOW YOU DESCRIBED HOW BLCL CURTAILMENT WORK.
IT SOUNDS LIKE THAT IS A PRETTY SAFE ASSUMPTION, BUT I'D YOUR POINTS TAKEN ON TIMING.
HEY MATT, CAN YOU HEAR ME? YES, WE CAN.
UH, I GUESS IF I MISS THIS, I APOLOGIZE.
UH, FOR THE NET METER LOADS, I THINK, YOU KNOW, IT WOULD BE GREAT IF OUR CART CAN PUBLISH THE TECHNICAL REQUIREMENTS FOR LARGE LOADS TO, YOU KNOW, WHAT ARE THE TELEMETRY REQUIREMENTS AND OTHER ASPECTS THAT ARE NEEDED TO BE, UH, YOU KNOW, IN SYNC WITH THE QC AND OUR CART.
UH, THE SOONER THE BETTER, UH, GIVEN, YOU KNOW, A LOT OF, UH, WELL SOME OF THESE ARE ALREADY UNDER CONSTRUCTION, SO IT WOULD TAKE A DESIGN CHANGE IN OTHER ASPECTS.
UH, CHRIS, I THINK THIS IS JUST, THIS IS PROBABLY PART QUESTION AND CHRIS, CAN YOU SPEAK UP A LITTLE? GO AHEAD.
SO I THINK THIS IS PART QUESTION, PART COMMENT.
UM, FOR WHEN ERCOT INTENDS TO DO THOSE INVOLUNTARY CURTAILMENTS, YOU KNOW, NOT ONLY FROM A MARKET PRI PRICING PERSPECTIVE, I THINK GENERALLY FROM A RELIABILITY AND REPORTING RESPECTIVE THO THOSE SHOULD BE CONSIDERED IN SOME SORT OF BROADER, UM, PUBLIC FACING REPORT ABOUT SORT OF UNSERVED LOAD OR UNSERVED ENERGY AND, AND KIND OF BLEED THROUGH INTO THE RELIABILITY METRICS SINCE WE ARE GOING INTO BASICALLY A MANUAL OR FORCED LOAD SHED ENVIRONMENT THEM.
SO JUST A GENERAL COMMENT, NOT SURE WHAT EXISTS ALREADY ON IT.
UM, WE HAVEN'T HAD TO, I GUESS, REALLY THINK ABOUT THIS TO YOUR POINT EARLIER.
UM, BUT I THINK IT SHOULD BE TRANSPARENTLY STATED IF WE ARE DOING THIS A LOT, WHY, YOU KNOW, WHAT IS THE CAUSE OF THAT IN THOSE THINGS? ALL RIGHT, THANK YOU CHRIS.
SO I WAS JUST WONDERING IF UH, IF, IF THERE'S GONNA BE AN OPPORTUNITY IN THE FUTURE TO DISCUSS HOW THE, WE'RE GONNA MANAGE THE UNDER FREQUENCY PRESCRIPTION SINCE DROPPING A LOT OF LARGE LOAD IS GONNA DRASTICALLY CHANGE THAT GOING INTO AN EEA THREE.
I MAY NEED A LITTLE MORE CONTEXT, BUT I CAN COME CHAT WITH YOU HERE ON THE SIDE.
I THINK IT'LL NEED TO BE A DEEP DIVE TOPIC.
SO IF YOU'RE PRESCRIBED AT 20%, YOU DROP A LARGE, A LARGE LOAD, YOUR PRESCRIPTION'S GONNA JUMP TO 30, 40 OR 50% PRETTY FAST.
SO YOU'LL NEED SOME KIND OF FLEXIBILITY AROUND HOW TO MANAGE THAT, MITIGATE THAT.
I THINK THAT'S A PRETTY DETAILED ONE WE WILL NEED TO TALK ABOUT.
'CAUSE IT'S ALMOST THE SAME THING AS THE FIRM LOAD SET TABLE.
HOW DO YOU ADJUST IT FOR IF THESE LOADS ARE ON VERSUS OFF?
[02:20:01]
SAME THING WITH THE U-U-F-L-S.CAN YOU CONFIRM? YOU CAN HEAR ME? WE CAN.
UM, JUST A SUGGESTION, I APOLOGIZE.
UM, AS I WAS GOING THROUGH THIS YESTERDAY, I KEPT GETTING LOST IN THE DIFFERENT NEW ACRONYMS. UM, AND I'M A BIG BELIEVER IN OUR ACRONYMS, BUT IF WE COULD, UH, THROW IN LIKE A GLOSSARY OR SOMETHING AT THE END UNTIL WE'VE DEFINED ALL THESE, IT'D BE REALLY, REALLY HELPFUL FOR UM, PEOPLE LIKE ME.
WE HAVE A FEW MORE MINUTES LEFT.
ANY OTHER QUESTIONS OR COMMENTS? AND AGAIN, I DID PUT IN THE CHAT THE NEXT MEETING IS FRIDAY, NOVEMBER 6TH.
UM, AND THAT I DID PUT IN NET'S EMAIL ADDRESS ALSO.
ALRIGHT, WELL THANK YOU TO THE ERCOT TEAM.
THANK YOU MARKET PARTICIPANTS FOR ALL BEING HERE.
UM, AGAIN, WE'LL SEND OUT A NOTICE WHEN WE'RE GETTING CLOSER TO THE NEXT WORKSHOP.
BUT THANKS FOR THE FEEDBACK AND WE LOOK FORWARD TO WORKING WITH Y'ALL ON THIS.