Meeting Summary - 05/20/2025 PLWG Meeting

1 - Antitrust Admonition

2 - Agenda Review

3 - Review of PLWG Meeting Minutes (April 29th)

▶️4 - PGRR120 – SSO Prevention for Generator Interconnection

• AEP and Lone Star discussed the PGRR120 with an emphasis on the grandfathering date, moving towards a 04/01/2026 date.
• AEP's original suggestion was 01/01/2026, but discussions leaned towards adjusting this date to allow more flexibility.
• AEP acknowledged that Lone Star's project list was more extensive, affecting their preference for the date.
• AEP and Lone Star reached a consensus on accepting ERCOT's comments and proposed a tabletop edit for the date.
• Lone Star expressed concern about projects affected by increased expenses, seeking exemptions for some projects, pending further legal discussion.
• Consensus was reached to conduct a desktop edit to update the date to 04/01/2026 and plan to move forward with the edits before the ROS meeting.
• Stakeholder feedback emphasized the importance of filing comments to ensure a clear paper trail through the approval process.
• Kristin Cook from Southern Power expressed satisfaction with the language of PGRR120 and acknowledged NPRR1280 as a potential mitigation strategy.
• Plans were made for NPRR1280 to be discussed in an upcoming PLWG meeting.

▶️5 - PGRR122 – Reliability Performance Criteria for Loss of Load

• John Ross Hubbard from TIEC highlighted concerns about codifying system limitations without clarity on outcomes if triggered, fearing a moratorium on interconnections.
• TIEC is particularly worried about the impact on regions like the Permian Basin due to unexpected load growth and modeling uncertainties.
• There is a suggestion for ERCOT to publish modeling parameters to assist developers in designing compliant facilities.
• TIEC suggests requiring Transmission Service Providers to offer potential transmission solutions for triggered load loss limits.
• Jeff Billo clarified that PGRR122 wouldn't create a moratorium on interconnections; operational decisions would determine this.
• There was a discussion on loads without ride-through capability and their impact on the 2,600 MW limit.
• Jeff Billo mentioned previous attempts at setting a standard large load voltage ride-through requirement received pushback.
• John Hubbard emphasized the need to codify what ERCOT's modeling tests for clearer developer guidelines rather than impose requirements on large loads.
• Concerns were expressed about functional moratorium due to modeling requirements yet Jeff stated ERCOT aims to ensure respectful adherence to system operating limits.
• Ken Donohoo highlighted differences in load characteristics like oil and gas versus AC loads across Texas, affecting voltage issues.
• Ken and Jeff discussed past voltage events and the impact of synchronous condensers and future 765 voltage support.
• Clayton Stice asked about progress on creating a load commissioning plan, which Agee Springer indicated was in development.
• Discussion on commissioning plans factoring in max load and load ramp schedules to ensure compliance over time.

• If a problem creates system risk, shutting down the load is the only operational solution, representing significant financial impact.
• Entities connecting to the grid need to be aware of potential issues in advance and work towards resolving them.
• Shedding load is considered a last resort; alternative solutions are being explored.
• Assumptions are being made in studies about loads tripping off based on the ITIC curve; alternatives exist if better performance settings are identified.
• A large load working group report is expected by June or July to discuss alternative solutions.
• There are regulatory challenges with implementing battery solutions on the grid side; load side batteries are considered an option for loads to solve issues independently.
• Concerns were raised about implementing operating limits instead of a moratorium on interconnections.
• ERCOT needs a mechanism to decide which loads to shut off without straightforward solutions in operational limits.
• Studies are underway to identify which loads cause problems, but ERCOT is not yet at the operational point of shutting loads off.
• The discussion includes the treatment of voltage-sensitive loads and consequential load loss in relation to limits.
• The limitations imposed by PGRR122 have broader implications, including potential delays for new connections awaiting transmission upgrades.
• Further comments and consensus are required before progressing to the board with PGRR122.
• ERCOT aims for identification of issues in the large load interconnection study rather than during operations to avoid disruptive load shedding or moratoriums.
• PGRR122, as a part of addressing loss of load issues, is a step within larger planning and operational strategies.

• Low confidence in current dynamic modeling of load demands; efforts are underway to improve these models.
• Conservative assumptions are currently applied to operations due to limitations in dynamic modeling.
• The issue of consequential load loss is discussed, particularly for loads sensitive to voltage with less than three tie lines, affecting interconnection limits.
• There is a need for future revisions to consider voltage sensitivity more comprehensively and possibly amend rules to support interconnection projects.
• Discussion on how draft rules potentially impact future projects, and recommendation for re-evaluation of studies by Load Customers for operational impacts.
• Clarification sought on which interconnection studies would fall under new rules; confirmation that specific studies like SSO analysis may not be necessary.
• Operational limitation considerations might focus on load ride-through characteristics.
• Discussion on the Permian region's future load interconnections and potential voltage ride-through standards.
• Holistic approach needed for long-term solutions, involving transmission options and possibly market-based solutions like battery energy storage.
• Emphasis on being cautious with predictions about future changes.

▶️6 - NPRR1272 – Voltage Support at Private Use Networks

• Melissa Trevino with Occidental commented that there were no formal comments seen initially.
• Comments have been submitted to ERCOT and are under review by market roles.
• A deep dive into the comments is underway, with plans to post them soon.
• The discussion will continue at the PLWG once written comments are reviewed.
• A question was raised regarding the applicability of the protocol section to future technologies such as renewables, solar facilities, SMRs, and gas-fired generators.
• Further clarification from ERCOT is requested for the market to better understand how the protocol would apply to these technologies.
• This item will be tabled and revisited in the next month's PLWG meeting.

▶️7 - PGRR124 - ESR Maintenance Exception to Modifications

• Discussion on PGRR124 regarding ESR Maintenance Exception to Modifications is ongoing.
• Eric Goff, Tesla, mentioned that discussions with ERCOT are happening.
• A meeting to discuss the item further is in the process of being scheduled.
• Scheduling conflicts are causing delays in having the meeting.
• The item is tabled for the next month with hopes for a more in-depth discussion.

▶️8 - NPRR1274 - RPG Estimated Capital Cost Thresholds of Proposed Transmission Projects

• NPRR1274 discussed adjustments to RPG tier thresholds for proposed transmission projects, last adjusted in 2017.
• ERCOT proposes a 35-40% adjustment based on the Consumer Price Index (CPI) tracker; Oncor expresses concerns.
• Oncor argues CPI doesn't reflect transmission project costs due to increased construction and material costs.
• Oncor recommends doubling tier thresholds again, considering significant cost increases in recent years.
• Specific facility costs for Oncor projects have increased by 90-100% in the last five years.
• Consideration of the increased frequency of ERCOT reviews for straightforward upgrades due to cost changes.
• Proposed changes by Oncor include moving tier one threshold from 100 million to 200 million.
• Joint TSP owners, including CenterPoint, support Oncor's view and submitted additional analysis.
• Jim Lee from CenterPoint highlights substantial increased costs from temporary construction methods and other factors.
• ERCOT acknowledges the conversation started by CPI adjustments and plans to further review the comments.
• TSP owners express willingness to collaborate with ERCOT for more accurate threshold adjustments.
• ERCOT intends to reach out to commenters for more project-specific information before filing additional comments.
• The NPRR decision is tabled to the next meeting, pending further discussion and ERCOT's review of comments.

▶️9 - Update - FAC-002 qualified change definition for end-user Facilities

Qualified_Change_Definition_Update_May_2025_PLWG.pdf

• ERCOT provided an update on the definition of qualified changes required by the new standard FAC-002-4, effective from January 1, 2024.
• The aim is to align qualified changes with existing ERCOT processes to avoid increasing stakeholder burdens.
• Formal processes for generation and transmission already exist; end-user facility changes were based on interim large load interconnection processes.
• With the approval of PGRR115 by the PUC, ERCOT plans to update its qualified change definition for end-user facilities.
• PGRR115 will become effective on July 1, with Agee Springer's team sending out market notices before implementation.
• The goal is to align the effective date of qualified changes for end-user facilities with the PGRR115 requirements.
• Updates to the current qualified change definition involved replacing interim process language with new language in planning guide section 9.2.1, paragraphs b and c.
• There was a discussion on the implementation schedule for PGRR115, with further details to be unboxed by June 1 and fully effective by July 1.
• Monica Jha from Vistra raised questions about defining 'material change,' which ERCOT agreed to consider within the context of developing a large load interconnection handbook.
• A market notice related to these changes is expected to be released soon, by June 1.
• The discussion concluded with thanks and confirmation of the next meeting date as June 17.

 10 - Review Open Action Items