Meeting Summary - 05/07/2025 WMS Meeting

▶️0 - Validation for WMS Standing Representatives

▶️1 - Antitrust Admonition

▶️2 - Agenda Review

▶️3 - Approval of WMS Meeting Minutes (Possible Vote)

• Motion to approve the April 2, 2025 WMS meeting minutes as submitted added to the combo ballot.

▶️4 - Technical Advisory Committee (TAC) Update

• NPRR1229 and NPRR1271 were discussed and approved by TAC.
• Acknowledgment of working groups and representatives for their work on these NPRRs.
• Anticipation of a firm fuel supply service expansion update with NPRR1275 later in the agenda.

▶️5 - WMS Goals/Strategic Objectives (Vote)

• Motion to endorse the WMS Goals/ Strategic Objectives as submitted added to the combo ballot.
• No feedback or redlines were received from the group since the preview last month.

6 - Demand Side Working Group (DSWG)

• No report posted and no representative available for verbal update.

▶️7 - ERCOT Operations and Market Items - 9:55 a.m.

▶️7.1 - ADER Discussion – Phase 3 Governing Document (Vote)

• The motion to endorse the ADER Phase 3 governing document concepts as described in the Vistra/Enchanted Rock proposal was carried with a 90% majority in favor.

7.1.1 - DSWG Report

• No report.

▶️7.1.2 - Voltus Presentation

07.-Presentation-on-Non-LSE-ADER-Participation_VOLTUS.pdf

• Kimaya Abreu of Voltus and colleague Youssef Shaker presented a proposal for Non-LSE participation in ADER, highlighting the expertise of third parties to grow ADER and bring megawatts to the market.
• Criticism was directed at Vistra's option two from the last WMS, as it poses barriers to third-party participation.
• Growth in ADER has been slow due to limited pathways for third-party participation, reflected in current participation limits.
• The presentation showcased the benefits of the NCLR model for third-party participation, contrasting it with added complexities under proposed carve-outs.
• A compromise at the task force meeting allowed third-party participation with over a 100 kW threshold, approved by a 17-4 majority vote.
• Youssef Shaker highlighted concerns from Vistra's arguments, including changes in load shape, reputational risks, and potential participation by smaller customers.
• The discussion involved evaluating how ADER participation impacts REPs' hedging strategies and customer energy usage variations without requiring prior consent from REPs.
• Concerns included reputational risks to stakeholders from ADER and the importance of transitioning to policies that support broader incorporation of smaller customers in the future.
• Recommendations included leaning towards an option that allows NCLRs to participate without changes and a compromise notice requirement in option two b to alleviate rep concerns.
• The presentation emphasized that third parties are crucial for DERs to grow within ERCOT, and highlighted the potential of increased participation by removing consent requirements.
• Questions from stakeholders, including the difference between LSE and REP terminology and the implications for NOIE's approval in customer participation, were addressed.
• A discussion on how Voltus’s proposal is beneficial for consumers, highlighting the increased potential for residential customer participation in future ADER phases.

▶️7.1.3 - Leap Presentation

07.-Leap-Presentation-for-May-7-WMS-Meeting.pdf

• Collin Smith, Regulatory Affairs Manager at Leap, presented on the value of third-party aggregators in the wholesale market.
• Leap operates as a demand response aggregator using a partnership model with DER technology providers to connect customers to wholesale markets.
• Active in deregulated markets across the U.S., including ERCOT's ERS program.
• Discussion on challenges and benefits of third-party participation in ADER (Aggregated Demand Response) program.
• The ADER program aims to integrate more DERs into ERCOT’s marketplace, improving grid reliability post-Winter Storm Uri.
• Current target unmet: Only 25 of 80 MW initially planned for Phase 1 of ADER have been enrolled.
• ERCOT's recent modeling predicts Texas load to nearly double by 2030, necessitating rapid ADER expansion.
• Competition in the electricity market benefits consumers through lower costs and increased choices.
• Current barriers exist due to QSE matching requirements, impeding third-party participation in ADER.
• Collin detailed historical efforts to expand ADER participation, emphasizing the need to remove barriers.
• Third-party aggregators have scalable models that can rapidly increase customer enrollments but face barriers under current protocols.
• Leap partners anticipate 80 MW capacity in 2026 if barriers are removed.
• Collin suggested accepting the current 100 kW threshold limit for Phase 3 while exploring further expansion.
• Resistance from some retail energy providers on amendments removing QSE requirements.
• Colin emphasized the necessity to streamline administrative processes for future ADER expansions.

▶️7.1.4 - Vistra Revisions

07.-Vistra-Enchanted-Rock-Presentation-for-May-7-WMS.pdf

• James Langdon from Vistra presented the proposal aimed at improving coordination with REPs when participating as NCLRs.
• The proposal, co-authored with Enchanted Rock, focuses on enhancing coordination for customer benefit.
• Vistra suggests an LSE acknowledgment form that mirrors the existing DSP acknowledgment form to verify coordination.
• The acknowledgement form aims to simplify ERCOT's verification process and avoid complexity associated with cross settlement.
• Supports the continuation from phase two and phase one to phase three, with necessary modifications for alignment in governing documents.
• Concern was raised regarding Voltus's issues that REPs might not respond or could terminate commitments early without cause.
• Monica Batra-Shrader from Enchanted Rock emphasized support for the Vistra proposal and open-mindedness towards compromises with Voltus.
• Discussion on customer privacy was raised, pointing out potential information sharing issues with customer data under Vistra's proposal.
• Concerns are expressed regarding administrative burdens on ERCOT and the importance of balancing customer privacy and administrative efficiency.
• A motion was proposed to endorse the Vistra proposal, recognizing the necessity for adjustments before finalization.
• Jim Galvin emphasized the need for third-party QSEs to bear related administrative costs to avoid market participant subsidization.
• Continuous dialogue indicated an overall interest in expanding third-party participation while balancing associated risks and controls.
• The final consensus focused on the importance of customer protection, data privacy, and effective program execution.

▶️7.1.5 - Tesla Revisions

07.-ADER-revisions-Tesla.pdf

• Eric Goff on behalf of Tesla presented proposed changes, emphasizing two main points: the inclusion of more ancillary services and concerns about program caps.
• Tesla argues for the resolution of issues regarding ancillary services to enhance retailer access and participation in phase four.
• There are concerns about the current cap on participation, which Tesla claims limits its customers and hinders the pilot's commercial viability.
• Tesla calls for the removal of caps to facilitate broader market participation, suggesting the pilot phase might have concluded its usefulness in this area.
• ERCOT representatives discussed the necessity of maintaining caps during the pilot phase to manage scope and learn from the process, with plans to potentially integrate changes into future market designs.
• Stakeholders, including ERCOT and other representatives, expressed opposition to removing caps, citing the need for pilot scope control and resource management.
• Suggestions were made to possibly extend discussions to reach a consensus before moving forward with proposed changes.
• The governing document for phase three includes the discretion to adjust limits, addressing some of Tesla's concerns.
• A vote was taken to move forward with the ADER phase three governing document concepts as proposed by VISTRA and Enchanted Rock, resulting in a 90% approval.
• Outcome: The motion to endorse the ADER phase three governing document concepts as described in the VISTRA Enchanted Rock proposal was carried with a 90% majority in favor.

▶️7.2 - 2025 Q1 Settlement Stability Report

07.-WMS_Settlement-Stability-Report_Q1_2025.pdf

• Presented by Magie Shanks from the ERCOT Settlements Group.
• No price changes occurred after settlement statements were posted for Q1.
• No resettlement due to non-price errors in Q1.
• 100% of disputes in Q1 resolved in a timely manner.
• Noticeable spike in settlement charges due to load differences in settlement runs.
• Data from 2011 to 2015 was removed to improve table visualization, retaining only the last ten years of data.
• Presentation of real-time and day-ahead total charges statistics.
• Details on ESI ID consumption data availability and load volume.
• Net allocation to load slide showed the RMR settlement beginning in March 2025.
• Securitization uplift and default charges highlighted.
• Jim Galvin raised concerns about ESI ID consumption load availability impacting financials due to certain large meters (IDR meters) not being included in initial settlements.
• Suggestion to analyze meter type issues in future sessions.
• Magie agreed to discuss this with the data aggregation and metering group for potential inclusion in future reports.

▶️7.3 - 2024 Annual UFE Report

06.-2024_UFE_Analysis_Report.pdf

• The UFE (Unaccounted for Energy) report presented by Joe Lara from ERCOT's data loading and aggregation unit.
• The negative UFE in 2024 indicates overestimation of load and losses.
• Total 2024 UFE was negative 4,080,762 MWh, costing $144 million.
• The negative UFE was consistent throughout 2024, particularly in May and August.
• Implementation of NPRR1145 in March 2025, shifting to state estimator-based calculations for loss factors.
• After this change, the average UFE dropped from an absolute value of 0.8% to 0.6%.
• Loss factors decreased from 3.19% to 2.4% after implementation.
• Post-implementation, UFE changed from negative to positive daily average values.
• Acknowledgement of Joe’s report and discussion about improved performance since NPRR1145 implementation.

▶️7.4 - 2025 Q1 and 2024 Annual Unregistered Distributed Generation (DG) Report Updates

07.-2024-Annual-and-2025-Q1-Unregistered-Distributed-Generation-DG-Report-WMS-Update.pdf

• The 2024 annual DG report totals just over 2,800 megawatts, excluding battery storage for the first time.
• This exclusion practice was initially applied in quarterly reports and has now been implemented in annual reports.
• Year-on-year growth in the annual report shows a 10% increase from 2023 to 2024.
• There is a difference in NOIE data between annual reports (all NOIE DG capacity) and quarterly reports (only NOIE with a two-megawatt threshold are included).
• The Q1 2025 quarterly report shows a DG total of slightly over 2,800 megawatts.
• The quarterly report excludes DG battery storage, reflected at the table's bottom.
• There was a 53-megawatt growth in the quarterly DG total from Q4 last year to Q1 this year.
• No questions were raised in the meeting related to this report.

▶️7.5 - RMR Life Cycle Uplift Costs Expected Over Next Few Months

• ERCOT is negotiating with Lifecycle and CPS to move 15 dual fuel combustion turbines to San Antonio from Houston.
• The move requires the turbines to run on diesel fuel as they will be installed in substations.
• ERCOT doesn't have a final agreement with Lifecycle yet, although they are close.
• CPS and Lifecycle are incurring significant costs without current means to recover payments.
• Estimated cost presented was approximately $54 million with $29 million for Lifecycle and $23 million for CPS.
• Payment system isn't operational yet due to absence of contract and QSE, anticipated to be CPS.
• Payments will start via a miscellaneous invoice once a contract and QSE are in place.
• Initially, costs will be calculated manually using spreadsheets until all resources are registered in the system.
• A system payment will replace manual calculation as more resources get registered.
• ERCOT plans to transition costs into the RMR settlement system eventually.

Questions and Responses

• Is there a process for notifying about miscellaneous invoices?
• ERCOT will issue market notices with details of weekly miscellaneous invoices.
• Are miscellaneous invoices burdensome?
• Yes, they are administratively burdensome for local entities like LCRA.
• Is there interest accumulation on these costs?
• No interest will be paid on top of these costs.

▶️8 - WMS Revision Requests (Vote)

Impact Analysis

▶️8.1 - Related to NPRR1264: COPMGRR051, SMOGRR031, and VCMRR043

• COPMGRR051, SMOGRR031, and VCMRR043 are related to NPRR1264.
• Waiting on PRS recommendation for NPRR1264 and development of the Impact Analysis (IA).
• No action needed at this time; items can remain tabled.
• The meeting proceeded to the language review.

Language Review

▶️8.2 - VCMRR044, RTC+B – Mitigated Offer Cap for Hydro Generation Resources

• Motion to recommend approval of VCMRR044 as submitted added to the combo ballot.
• The item discussed was VCMRR044 regarding mitigated offer caps (MOCs) for hydro generation resources.
• The VCMRR was initiated due to a key principle approved during RTC meetings years ago.
• Hydro resources not operating in synchronous condenser mode should have energy offer caps equal to MOCs.
• Since hydro resources in synchronous condenser mode are not dispatched by SCED, the simplest solution is to set MOCs equal to the real-time system-wide offer cap for all hydro resources.
• This proposal was previously discussed in RTC+B meetings, and task force members have seen the language.
• The proposal is now officially submitted.
• LCRA is comfortable with the proposal.

▶️8.3 - SMOGRR032 and SMOGRR033

• Motion to recommend approval of SMOGRR032 and SMOGRR033 as submitted added to the combo ballot.
• SMOGRR032 and SMOGRR033 are administrative changes with no substantive impact.
• The updates involve adding a new OBD and updating references in related sections.
• Both documents have been reviewed by the meter working group.
• There is support for grouping these updates as combo ballot candidates and no concerns were raised by the group.

▶️9 - NPRR1255, Introduction of Mitigation of ESRs (Possible Vote)

• Motion to request PRS continue to table NPRR1255 for further discussion at CMWG added to the combo ballot.
• The NPRR1255 was introduced at the CMWG in September 2023, aiming to address energy storage resources (ESRs) and market power issues.
• The NPRR sets a high threshold with a light-touch in terms of mitigation framework considering ESRs' unique challenges.
• Mitigation applies if an ESR shows market power and a shift factor of 20% or more, impacting less than 1% of hours in a backcast analysis.
• An additional threshold considers stored energy, exempting resources with less than 25% state of charge from mitigation, defaulting to system-wide offer caps.
• Concern was expressed about this approach not accounting for battery duration, particularly with two-hour batteries.
• The need for stakeholder clarification on implementation and further integration with RTC was highlighted.
• Risk management for ESRs in the context of the RUC capacity short and potential mitigation was discussed.
• The decision was to refer this NPRR to the CMWG for further refinement, particularly concerning the 25% filter and integration examples with RTC.

10 -New Protocol Revision Subcommittee (PRS) Referrals (Vote)

▶️10.1 - NPRR1275, Expansion of Qualifying Pipeline Definition for Firm Fuel Supply Service in Phase 3

• Motion to request PRS continue to table NPRR1275 added to the combo ballot.
• ERCOT filed comments after the April 24 open meeting recommending to keep the item tabled.
• Comments from the commission indicated interest in opening a rulemaking to address program expansion issues.
• A previous request was made for a list of issues to inform commission staff, but it's recommended not to pursue that and instead let the rulemaking process guide the commission.
• There was uncertainty if the commission's PUC rulemaking calendar included firm fuel supply deliberations.
• Matt Arth from ERCOT confirmed that ERCOT supports keeping NPRR1275 tabled pending further commission action.
• It is believed that the commission intends to open a rulemaking in the future, though it was not scheduled for the upcoming open meeting.
• Concerns were expressed about pointing to the commission for rulemaking if it's not on their proposed agenda.
• Discussion of NPRR1275 is set to be tabled with the possibility of future revisiting, aiming for revisions by the 2026-27 procurement period.
• Brittney Albracht highlighted the procedural aspect; NPRR1275 was referred to WMS and requires a response, even if just to request further tabling.
• The decision was made to put NPRR1275 on the combo ballot for tabling at the current time, awaiting further direction from TAC discussions.

▶️11 - Revision Requests Tabled at PRS and Referred to WMS (Vote)

▶️11.1 - NPRR1070, Planning Criteria for GTC Exit Solutions

• NPRR1070 is pending comments from EDF.
• No discussion is expected during the meeting.

▶️12 - Meter Working Group (MWG)

• No report posted and no representative available for verbal update.

▶️12.1 - NPRR1263, Remove Accuracy Testing Requirements for CCVTs (MWG) (Possible Vote)

• Additional month requested to discuss NPRR1263.
• Update on NPRR1263 expected in the next meeting.

▶️13 - Supply Analysis Working Group (SAWG)

13.-250507-SAWG-presentation-to-WMS-v1.pdf

• Third version of long-term load forecast presented.
• Coal to gas inclusion discussed in the CDR report.
• New process overview presented at SAWG by Kate Lamb and Sam Morris.
• Contracted loads not necessarily included in the current study process.
• Current data centers curtailed only during extreme price events.
• Load reduction is about 10% of peak load.
• Consultant to prepare a global to local analysis of chip use impacting the ERCOT region expected in late fall or early winter.
• Historical data showed only 26% of offshore loads were realized.
• ERCOT preparing and publishing hourly load forecasts up to 2044.
• Also preparing Hourly load forecasts based on weather data from 1980 to 2023.
• Planned update of ERCOT load forecasts in February or March 2026.
• ERCOT's proposed strategy for coal gas conversion discussed.
• Creation of a new unit status code for unconfirmed plan fuel conversion: OPER-UNFC.
• Changes won’t require a new NPRR, but future NPRR will enhance transparency.

13.1 - NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service (SAWG) (Possible Vote)

• Not discussed

▶️14 - Combo Ballot (Vote)

• Motion to approve the combined ballot as presented passed unanimously with no abstentions.

▶️15 - Congestion Management Working Group (CMWG)

15.-CMWG-update-WMS-Apri-2025.1.1.pdf

• Updates provided on the CRR auctions; peak weekday case took longer hours to solve than before, at 203 hours.
• Discussion on introducing new transaction limits for 2025 auction sequence; these are temporary limits.
• Consideration of a NPRR regarding the removal of multi-month bidding functionality and option pricing report.
• Plans for the NPRR to increase the minimum base quality from 0.1 MW to 1 MW under discussion.
• ERCOT presented information on record high LMPs from February 19, 2025; stakeholders discussed ideas to prevent similar events.
• Consideration of IMM application to address high price situations; more analysis needed.
• Updates were provided on point-to-point obligation bids and potential correlations with execution times.
• Vistra introduced a proposal for more granular CRR TOU blocks to improve auction speed and efficiency.
• The proposal considered more targeted products dividing solar and non-solar hours to efficiently hatch obligations and speed up CRR auction clearing.
• All proposed changes must undergo the regular change process and work through different working groups.

▶️16 - Wholesale Market Working Group (WMWG)

16.-wmwg-update-to-wms-of-may-05-meeting.pdf

• Amanda Frazier presented the WMWG update.
• ERCOT presented on the RUC process, explaining inconsistent or confusing reasons for RUCs due to multiple factors.
• Encouragement to review the presentation.
• Constellation proposed an NPRR concerning the opt-out timing for RUC due to the current two-hour notice requirement.
• The new NPRR will be filed and discussed in the future.
• ERCOT proposed MDRPOC changes to create more headroom for planned outages, with a market notice expected possibly by the end of the month.
• Feedback opportunity for stakeholders when the notice is filed.
• TCPA's Bill Barnes agreed ERCOT's proposal addresses current concerns and introduced additional proposals for more certainty and flexibility in scheduling outages.
• Potential protocol changes might be required, with commitments to file NPRRs if necessary.
• Magie Shanks from ERCOT presented clarifications on emergency settlements changes, not protocol changes but interpretations of current protocols.
• ERCOT's previous approach considered all generators eligible for resettlement; now, eligibility is reevaluated based on protocol interpretations.
• Stakeholders encouraged clarification in the protocols despite agreement with ERCOT's interpretation by some market participants.

▶️17 - Other Business

▶️17.1 - 2026 Block Calendar

• Suzy Clifton from ERCOT facilitated the review of the calendar process and changes.
• The block calendar is reviewed annually and does not require a vote but outlines anticipated scheduling.
• TAC has approved their schedule, and WMS needs to confirm theirs.
• Any needed modifications will be made later in the year if issues arise.
• Agreement on the schedule will lead to posting within the next month.
• Feedback or concerns from the group are requested within a week if there are any.
• The schedule is consistent with previous years, with meetings on the first Wednesday of the month, adjusted for holidays.
• There are consistent meeting dates with both the TAC and the board from the previous year.
• General agreement in the meeting to proceed with the proposed calendar.

▶️17.2 - Review Open Action Items

• Discussion on completion of NPRR1190 related action item. The group agreed it was complete.
• Shane Thomas from Shell and CMWG vice chair mentioned the review of the CRR calendar methodology and timing is still pending.
• The group is considering retaining the review on the agenda for further validation.
• No concerns were raised about striking items considered complete.
• Acknowledgement of oversight in updating the list but consensus to keep reminders moving forward.

▶️18 - Adjourn