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  • Item 0 - Validation for WMS Standing Representatives - Pamela Hanson
    00:00:19
    Good morning WMS. This is Pamela Hanson from ERCOT.
  • 00:00:23
    We'll get started in a few minutes. First, some reminders to
  • 00:00:27
    help the meeting go more smoothly. Please remember to
  • 00:00:30
    place your first and last name alongside who you represent
  • 00:00:33
    in the WebEx name. We have a managed queue
  • 00:00:37
    if you'd like to join the discussion, please place your name in the chat.
  • 00:00:41
    Please remain on mute until the chair recognizes you.
  • 00:00:44
    We vote by ballot. When it's your segment's turn to vote,
  • 00:00:47
    please remember to unmute and check that you're not double muted,
  • 00:00:51
    and then return to mute after you have voted. Should the meeting or
  • 00:00:55
    audio end unexpectedly, please log back in using
  • 00:00:59
    the same Webex information posted to the meeting page. Mister Blake,
  • 00:01:03
    you have quorum whenever you're ready to begin.
  • 00:01:07
    Very good. Thank you Pamela. Welcome to July WMS,
  • 00:01:12
    everyone, members and guests, glad to have you here online.
  • 00:01:17
    It's been an exciting July already and we
  • 00:01:22
    have quite a few things to discuss today and so we'll get into that.
  • Item 1 - Antitrust Admonition - Eric Blakey
    00:01:28
    I want to first go through the antitrust admonition
  • 00:01:32
    and Brittany or Pamela, if we could put that on the screen.
  • 00:01:36
    I believe there it is. So if you could review
  • 00:01:39
    the antitrust admonition, please let us know you have
  • 00:01:43
    any questions or concerns and the disclaimer about presentations getting
  • 00:01:49
    into the agenda review and just
  • Item 2 - Agenda Review - Eric Blakey
    00:01:52
    want to first acknowledge the hurricane this week and we
  • 00:01:55
    know that especially in CenterPoint territory, they are
  • 00:02:00
    working quite a bit, obviously on recovery and
  • 00:02:04
    we just want to have a little recognition
  • 00:02:07
    of them and all the workers that are involved in that and appreciation to
  • 00:02:11
    them noted. It could affect our meeting today,
  • 00:02:15
    and we will do our best to work around that.
  • 00:02:19
    But we do want to at least acknowledge that that
  • 00:02:22
    has happened and we appreciate everyone
  • 00:02:26
    that is involved in that restoration. It's a
  • 00:02:29
    significant effort. So I also want to just
  • 00:02:33
    mention everyone knows about the spectrum outage, and so
  • 00:02:37
    we're going to try to keep things running today. But if for
  • 00:02:41
    whatever reason the spectrum outage
  • 00:02:44
    continues or it knocks us offline, just want to remind
  • 00:02:48
    folks about what Pamela said about dialing
  • 00:02:51
    back in using the regular WebEx or look
  • 00:02:55
    on email for updates.
  • 00:02:59
    Hopefully that won't happen today, but just want to acknowledge that
  • 00:03:03
    could help, could happen and affect our meeting.
  • 00:03:07
    We do have some proxies and alternate reps
  • 00:03:13
    to announce. Mark Smith in the consumer segment has
  • 00:03:17
    designated Eric Schubert as his alternate rep, Bill Barnes in
  • 00:03:20
    the IREP segment has designated Anish Pagani as his
  • 00:03:24
    proxy, and Resbie Strindon has designated Shane
  • 00:03:28
    Thomas alternate rep. We also have one new member to
  • 00:03:32
    welcome and that's Robert Anklem. He is in the IPM
  • 00:03:35
    segment with national grid. And so welcome, Robert. We're glad
  • 00:03:39
    to have you on board. And so
  • 00:03:44
    as far as the agenda review, we did have a new agenda
  • 00:03:49
    sent yesterday, and the one change
  • 00:03:52
    is in item five. The IMM CARD analysis
  • 00:03:57
    was added. And so we'll have Andrew Reimers have that presentation.
  • 00:04:03
    Otherwise, we just have the normal
  • 00:04:08
    working group reports and NPRRs.
  • 00:04:12
    They'll be under review.
  • Item 3 - Approval of WMS Meeting Minutes - Vote - Eric Blakey
    00:04:17
    Let's see. So let's
  • Item 3.1 - June 5, 2024
    00:04:21
    go to item number three, which is approval of WMS
  • 00:04:25
    meeting minutes from our June 5 meeting.
  • 00:04:28
    And I wanted to see if we could put those on the screen.
  • 00:04:31
    Thank you. These were distributed,
  • 00:04:35
    I believe, yesterday. I wanted
  • 00:04:38
    to see if anyone had any questions or comments or edits.
  • 00:04:45
    ERCOT, can you confirm whether you receive any comments or not?
  • 00:04:51
    Nothing received. Thank you. Great.
  • 00:04:55
    So I want to. Is there any opposition to adding
  • 00:04:59
    this to the combo ballot?
  • 00:05:09
    Okay, great hearing. No concern.
  • 00:05:13
    We will add that to the combo ballot. Next, we have the Tac
  • 00:05:16
    update. Jim represented WMS at the last TAC meeting. So,
  • 00:05:20
    Jim, I'll let you give this report. Hey, thanks,
  • 00:05:23
    Eric. Quick mic check. Make sure you guys can hear me.
  • Item 4 - Technical Advisory Committee - TAC - Update - Jim Lee
    00:05:26
    Yes, sir. All right, great. Thanks. So at the last TAC
  • 00:05:31
    meeting, TAC did
  • 00:05:35
    approve all of the voting items that were in front of them,
  • 00:05:40
    particularly to WMS. We had NPRR1216
  • 00:05:44
    the implementation of the emergency pricing program
  • 00:05:49
    that was approved along with its related OBDRR051
  • 00:05:52
    and VCMRR039.
  • 00:05:57
    TAC also took up NPRR1190 and approved
  • 00:06:01
    that, as well as NPRR1215 clarifications
  • 00:06:06
    to the DAM energy only offer calculation in NPRR1225,
  • 00:06:11
    exclusion of lubbock load from securitization charges. And then lastly,
  • 00:06:15
    PGRR106, which clarifies the projects to be included
  • 00:06:19
    in the Tippet report. And so all of those went,
  • 00:06:24
    moved forward as expected.
  • 00:06:28
    If you all recall, there was an
  • 00:06:32
    item where WMS leadership was seeking
  • 00:06:35
    feedback from TAC on any additional actions WMS
  • 00:06:39
    should take related to the new EPA rules,
  • 00:06:42
    and more particularly the greenhouse gas rule and the mercury and
  • 00:06:46
    air toxic standards rule, and which was presented
  • 00:06:50
    also as part of the CEO update at the board from
  • 00:06:54
    Pablo. And so the feedback that
  • 00:06:57
    WMS received from TAC was to keep this
  • 00:07:01
    on our radar and for the working groups
  • 00:07:04
    that are assigned Winwig and
  • 00:07:08
    SAWG, that we continue keeping an eye
  • 00:07:11
    on any additional developments. And then I kind of have this on our
  • 00:07:15
    agendas for discussion as warranted. And so
  • 00:07:19
    I know that the TAC assignment is a little bit
  • 00:07:24
    squishy. Right. There's, there's some language there that,
  • 00:07:28
    you know, has WMS looking at, you know, the proposed
  • 00:07:32
    EPA rules, too. And so, you know,
  • 00:07:35
    I know it's a little bit, like I said, a little bit squishy, but,
  • 00:07:39
    you know, just to kind of move forward with an
  • 00:07:44
    eye on any, any updates or developments to the EPA rules and
  • 00:07:47
    just keep those on our radars. So that is
  • 00:07:53
    all I had. Eric, for tech update kind of went through that kind
  • 00:07:56
    of quick, but if there's any questions, I'm happy to answer those.
  • 00:08:01
    No? Great report, Jim. Any. Any questions for Jim?
  • 00:08:06
    Just as a reminder, we're using the queue on WebEx,
  • 00:08:11
    and so if you have a question or comment, please just
  • 00:08:14
    make a note in the chat and we will call on
  • 00:08:19
    you accordingly. Any questions?
  • Item 5 - ERCOT Operations and Market Items
    00:08:23
    Okay, let's go to item five. ERCOT operations and
  • 00:08:26
    market items. Auction revenue distribution CARD
  • 00:08:30
    and CRR balancing account.
  • 00:08:33
    CRRBA. Calvin, are you on the line?
  • 00:08:37
    We are, yeah. Go ahead, David. I was just going
  • 00:08:41
    to tell him we've had a change of presenters.
  • 00:08:44
    Yes, sir. So, Eric, actually, this is Dave Maggio. I'll be kicking it off.
  • 00:08:47
    And then we also have Randy Roberts, who's going to jump in. I'll provide
  • 00:08:51
    some, somewhat of an introduction once we pull the slides up,
  • 00:08:54
    and then Randy will kind of take it from there.
  • 00:09:02
    Pamela, we had up. There we go. Thank you very much. We can go to
  • 00:09:05
    the second slide, please.
  • Item 5.1 - Auction Revenue Distribution CARD and Calvin Opheim
    00:09:11
    All right, so, I guess just to kind of quickly set the stage here,
  • 00:09:16
    wanted to let the WMS membership know that what
  • 00:09:20
    we like today, or do today is discuss a topic
  • 00:09:23
    that's been. Been coming up and that we've been having some one off conversations
  • 00:09:27
    on. The idea here is to kind of walk
  • 00:09:31
    through the problem and a couple of options that we've been talking
  • 00:09:35
    to people about. We have a particular preference, but there's a
  • 00:09:39
    few options that we have been thinking about with others.
  • 00:09:44
    The hope is, as we talk about these options and talk about
  • 00:09:47
    the concern, is if we can do that introduction today,
  • 00:09:51
    folks can have some time to think about it. We can have some more detailed
  • 00:09:55
    conversation next month and perhaps get an
  • 00:09:58
    endorsement on an option for how to pursue this moving
  • 00:10:02
    forward at the meeting next month in August.
  • 00:10:05
    As I mentioned, we've been talking about this topic with
  • 00:10:09
    a few interested parties, but it's really time to kind of talk about
  • 00:10:12
    this with the broader group and really lay out the three options that are out
  • 00:10:16
    there and then sort of following the discussion
  • 00:10:20
    and following, hopefully, an endorsement from WMS. The idea is that we
  • 00:10:23
    go back and incorporate that option into an NPRR
  • 00:10:27
    that we would file along with the associate impact analysis.
  • 00:10:31
    So that's kind of where we like to see this go over the
  • 00:10:35
    next couple of months here. Next slide,
  • 00:10:38
    please.
  • Item 5.2 - CRR Balancing Account - CRRBA
    00:10:41
    So what are we really talking about? This is getting into the
  • 00:10:45
    methodology for how we do the allocation
  • 00:10:49
    of the congestion revenue. Right, auction revenues or
  • 00:10:52
    CARD, if folks remember, there was an NPRR
  • 00:10:56
    probably a couple of years ago now, where we
  • 00:11:00
    had looked to revisit how this allocation worked.
  • 00:11:04
    So historically for everyone, and actually still
  • 00:11:07
    technically under the rule today, because 1030 has not been implemented,
  • 00:11:11
    the allocation of congestion
  • 00:11:15
    revenue. Right. Auction revenues is driven by
  • 00:11:19
    relative consumption, the load ratio shared during the peak interval
  • 00:11:24
    of any given month.
  • 00:11:27
    Under 1030. What we had originally
  • 00:11:30
    proposed was to essentially move from doing that
  • 00:11:34
    based on a peak interval to doing that more spread across the
  • 00:11:38
    totality of the month, sort of a monthly load ratio share.
  • 00:11:41
    And the reason that we were looking to revisit this is that we were seeing
  • 00:11:46
    behavior at the DC Ties specifically for exports,
  • 00:11:50
    where they were being scheduled in a manner that was intended
  • 00:11:54
    to increase the share of CARD in cases
  • 00:11:58
    where just looking at it on its own, the DC export
  • 00:12:02
    transaction didn't seem to make much sense economically. So effectively,
  • 00:12:06
    what we're seeing is this incentive to increase relative
  • 00:12:09
    consumption during the peak interval of the day, I'm sorry,
  • 00:12:13
    the peak interval of the month, for really the purpose of
  • 00:12:17
    maximizing CR auction revenue, as opposed to. Because it
  • 00:12:21
    makes sense relative to the prices in the real time market.
  • 00:12:26
    So, as I mentioned with the original NPRR, we had proposed
  • 00:12:29
    to move to a load ratio share across the whole
  • 00:12:33
    of the month, and this would have applied to all load at
  • 00:12:38
    the time. There were some commenters who were concerned about changing
  • 00:12:42
    it for everyone. Again, the particular concern that we
  • 00:12:45
    were looking at was behavior related to DC Ties. And so
  • 00:12:49
    the proposal and compromise that we landed with NPRR1030
  • 00:12:54
    was to essentially just change it for DC Tie exports
  • 00:12:58
    and to leave it alone for everyone else. And this is what was
  • 00:13:01
    ultimately approved and is sitting right now in gray box
  • 00:13:04
    for NPRR1030.
  • 00:13:08
    More recently, ERCOT and some others and Andrew will talk about
  • 00:13:12
    this a little bit as well, from the WMS point of view.
  • 00:13:15
    But we have become more concerned in sort of hearing
  • 00:13:18
    things that now this issue can exist for loads that
  • 00:13:22
    are more flexible and controllable. And this really isn't only a DC type
  • 00:13:26
    export problem anymore. So we'd like to kind of talk about the
  • 00:13:30
    issue, talk about some of the various options,
  • 00:13:33
    and then hopefully be able to move forward with a solution that comes
  • 00:13:37
    up with something that can apply to all load in some
  • 00:13:40
    form or fashion, as opposed to only being applied to DC type exports,
  • 00:13:44
    as was envisioned under what was approved with 1030.
  • 00:13:48
    So that's sort of the background. Before I turn it over to Randy
  • 00:13:52
    to talk through the options, any questions on that part of it?
  • 00:13:59
    Seeing none in the queue or not hearing anyone, I'll turn it over to Randy
  • 00:14:02
    to walk through the options. Thank you. All right,
  • 00:14:10
    well, someone please confirm you can hear me.
  • 00:14:14
    We hear you. All right, so,
  • 00:14:18
    our ERCOT preferred option is what we
  • 00:14:21
    originally proposed in the NPRR1030 is just the full
  • 00:14:25
    monthly load ratio share. So, total energy for the
  • 00:14:29
    queasy for the month divided by the total ERCOT,
  • 00:14:34
    we prefer that, mainly because it guarantees
  • 00:14:38
    we've solved this problem. So, the other
  • 00:14:42
    option that's been talked about, I'm calling alternate option
  • 00:14:45
    one, and that is using a
  • 00:14:49
    daily load ratio share based upon
  • 00:14:52
    the same day that we used before, where we found
  • 00:14:56
    the 15 minutes peak for the month. So we still
  • 00:14:59
    identify the 15 minutes peak for the month,
  • 00:15:03
    identify that day, and then, instead of just using
  • 00:15:07
    the peak interval, use the entire day's volumes to
  • 00:15:11
    calculate load ratio share.
  • 00:15:14
    The other option that we have talked about is using both of
  • 00:15:18
    those two options, but blending the two together,
  • 00:15:23
    and we,
  • 00:15:26
    in such a manner as both of them contribute to the
  • 00:15:29
    final load ratio share. And we would allocate
  • 00:15:33
    some percentage of 100 to each option and
  • 00:15:38
    then use that blended option. And if
  • 00:15:42
    we did go with that option, ERCOT would prefer at least
  • 00:15:45
    a minimum of 50% going to the monthly.
  • 00:15:50
    And if we can open up that spreadsheet document,
  • 00:15:55
    I can talk through that option a little bit more
  • 00:15:58
    in details.
  • 00:16:03
    So, this is that this spreadsheet can
  • 00:16:07
    calculate. It's producing the values over an e
  • 00:16:11
    by looking at the input data in B for
  • 00:16:14
    the right now, it's set on 50 and 50%.
  • 00:16:19
    So if you look, what's happening is that
  • 00:16:23
    combined weighted volume is going to be 50%
  • 00:16:26
    times the monthly peak day total,
  • 00:16:30
    plus 50% times the monthly total
  • 00:16:34
    divided by the number of days. And that's
  • 00:16:39
    getting to a combined weighted volume. And then
  • 00:16:43
    it's just a straight load ratio share from there.
  • 00:16:47
    And the row 17 below,
  • 00:16:51
    those are the. The answers for
  • 00:16:54
    the different, different weighting options.
  • 00:16:58
    So, the first column in a, it's 100%
  • 00:17:02
    peak day weighting, 0% monthly.
  • 00:17:05
    And then I just kind of went through and put in different options and put
  • 00:17:09
    them down there so people could see how they vary
  • 00:17:12
    by changing the weighting percentages.
  • 00:17:20
    So that's really all I have for this part.
  • 00:17:23
    And I, if anyone has questions on this. We can take them now,
  • 00:17:27
    but we are going to have. The IMM is going to have their presentation.
  • 00:17:31
    So if it's more of a broad question,
  • 00:17:34
    then it may be best to wait until after IMM's
  • 00:17:38
    provided their presentation. Hey, Randy,
  • 00:17:41
    I think there's a couple of folks in the
  • 00:17:45
    queue. I think it's about your proposals. Let's just
  • 00:17:49
    try it. And then if we need to hold it till after the IMM,
  • 00:17:53
    we can do that as well. But the first in the queue is Bryan Sams.
  • 00:17:56
    Bryan, can you go ahead?
  • 00:18:02
    Yeah, I can see the question.
  • 00:18:05
    Yeah, sorry, I get off the mute.
  • 00:18:09
    Oh, yeah. I can't really say there's.
  • 00:18:12
    I can't really say anyone's advocating for option two. I can
  • 00:18:16
    just say in the discussions we've had with some external folks,
  • 00:18:20
    we've just discussed all three of these options.
  • 00:18:25
    Okay. So there's no strong advocate for something versus
  • 00:18:29
    your preferred option? I wouldn't. I'd say. I don't know
  • 00:18:32
    that yet because the external communication has
  • 00:18:35
    been pretty limited. Okay, thank you.
  • 00:18:39
    Yeah. Thank you. Bob Wetmeyer? Yeah. Can you
  • 00:18:42
    hear me okay? Yes, sir. All right, good.
  • 00:18:47
    So I'm trying to dust off some cobwebs here. Back when we
  • 00:18:50
    originally did CARD, as I remember, CARD was
  • 00:18:54
    done to give money back to loads based
  • 00:18:59
    on primarily the load zone that they were in.
  • 00:19:03
    And we had used the peak load as
  • 00:19:07
    a proxy for the amount of energy they would consume.
  • 00:19:11
    Am I. Am I remembering that right?
  • 00:19:18
    Okay. Nobody else remembers either. If I am,
  • 00:19:21
    it does seem like the ERCOT preferred
  • 00:19:24
    option might be the better way to go if I'm
  • 00:19:28
    remembering why we did CARD. Right. But somebody can correct me later.
  • 00:19:31
    Thanks.
  • 00:19:37
    Do you have any comments on that, Randy? Or.
  • 00:19:41
    I definitely can't comment to the history of the CARD because that's something I'm not
  • 00:19:45
    the SME on. Okay. Okay.
  • 00:19:50
    I think you jumped in. You want to jump in on that? Yeah, I guess
  • 00:19:53
    I'm saying. Actually, I don't think I was part of the group that
  • 00:19:57
    helped design CARD originally. I think the.
  • 00:20:01
    I would say my understanding of the history and maybe is the better way to
  • 00:20:04
    describe it is that the. And I
  • 00:20:08
    guess to Bob, to your point, there's sort of two components of CARD.
  • 00:20:13
    There's a component of that for revenues that are
  • 00:20:16
    within a given zone, and then there's separately CARD that's sort
  • 00:20:19
    of across zone. So there's a little bit of a distinction and kind
  • 00:20:23
    of get into the nuance there of things that are
  • 00:20:28
    revenues that are, quote, unquote, within a zone versus revenues that are
  • 00:20:32
    across zones and done on a system wide basis.
  • 00:20:35
    The. But I think the. I'm sorry, go ahead, Bob. I think, Dave,
  • 00:20:39
    the concept was still the same. I do.
  • 00:20:43
    Difference. I think the concept was still the same, though. Yeah, the same.
  • 00:20:46
    The same sort of the same snapshot or whatever you like to call it was.
  • 00:20:50
    Was used regardless, or is used regardless of whether or not we're talking about
  • 00:20:54
    sort of inter versus intra zonal
  • 00:20:58
    congestion and revenues. I mean, I think part of the intent
  • 00:21:02
    was at the time thinking,
  • 00:21:04
    well, load really isn't flexible in such a way
  • 00:21:08
    to necessarily to respond to an incentive like
  • 00:21:12
    this. And that typically we probably see higher levels
  • 00:21:16
    of congestion at the peak times of the month. So should there
  • 00:21:20
    be some linkage between the relative
  • 00:21:23
    peak consumption and the revenues associated
  • 00:21:27
    with the congestion hedging. So I think that was at least the idea
  • 00:21:30
    of trying to link it to the peak of
  • 00:21:33
    the month. But, you know, I think
  • 00:21:37
    enough has changed that that really needs to be entirely revisited
  • 00:21:41
    and obviously why we've landed where we have ERCOT production.
  • 00:21:47
    Thank you. Thank you.
  • 00:21:51
    Next in the queue is Blake Holt. Blake. Go ahead,
  • 00:21:54
    Blake Hold, LCRA. I'll just jump in on this topic real
  • 00:21:58
    quick. My understanding is largely the same as Dave's.
  • 00:22:01
    I think the current approach of receiving payback
  • 00:22:05
    in the peak interval was an attempt to offset higher load costs
  • 00:22:09
    that native load would experience. Or at least
  • 00:22:12
    that's my general understanding of the concept
  • 00:22:15
    there. I want to reserve our opinion on these
  • 00:22:19
    options until after the IMM gets a chance to
  • 00:22:23
    present. But I did want to touch on something that Dave commented
  • 00:22:26
    on. Dave, I'm curious how you
  • 00:22:30
    all caught this activity you mentioned. You heard,
  • 00:22:34
    heard. Maybe some folks talk about it, or were you all actually able to
  • 00:22:37
    witness it in the data?
  • 00:22:41
    I would say our
  • 00:22:44
    observations is probably very limited.
  • 00:22:48
    I think we've heard it more anecdotally. I will
  • 00:22:51
    say too, just simply the fact that we do
  • 00:22:55
    now have many more of these loads that are flexible
  • 00:23:01
    and able to respond in a way that's unique from what we've
  • 00:23:04
    historically seen, probably warrants
  • 00:23:08
    the review, regardless of probably even if we hadn't necessarily been hearing
  • 00:23:12
    some of these conversations and rumblings.
  • 00:23:17
    Okay, I guess. And just to go back in part of the history that is
  • 00:23:20
    distinct from, I think there was more direct observations
  • 00:23:25
    that were related to the original development of
  • 00:23:28
    1030 and DC Tie export behavior,
  • 00:23:32
    if my memory is correct. Yeah. Just to expand
  • 00:23:35
    on that a little bit, you'll have the ability to
  • 00:23:39
    see this activity from the DC Tie perspective,
  • 00:23:43
    but not necessarily from a flexible
  • 00:23:47
    load perspective, is that correct?
  • 00:23:51
    I mean, in both cases, we actually have the ability
  • 00:23:55
    to look at consumption and exports and what's
  • 00:23:58
    happening. What obviously becomes complex,
  • 00:24:02
    and probably even more so when it's low versus DC type exports,
  • 00:24:06
    is flagging it as clearly
  • 00:24:10
    uneconomic. I think that has always been more the challenge in just observation
  • 00:24:14
    of actual, obviously, the flow of energy in real time,
  • 00:24:19
    and just one more and then I'll stop. So it's more of a concern
  • 00:24:23
    on an uneconomic or economic
  • 00:24:27
    transaction. You'll determine that on your end, rather than
  • 00:24:31
    the classification of a load. For example,
  • 00:24:35
    NPRR1234 seeks to create
  • 00:24:39
    some classes of different types of large loads. If you all
  • 00:24:42
    were to be able to have greater insight into
  • 00:24:46
    flexible loads, it still wouldn't help solve
  • 00:24:51
    this issue. Or you couldn't splice out flexible loads to
  • 00:24:54
    settle them differently like you potentially could with DC Ties in 1030.
  • 00:24:59
    Is that correct? I mean, I. So if.
  • 00:25:03
    If they were somehow flagged. I'm sorry, maybe they'll try and make a little distinction
  • 00:25:07
    in your question that if they were somehow we had certain
  • 00:25:11
    loads that were flagged distinctly within, for example,
  • 00:25:14
    a network model, I mean, theoretically, we could create
  • 00:25:17
    different treatment. The. You know,
  • 00:25:21
    so, I mean, that that is technically feasible. The,
  • 00:25:26
    I will say, kind of going to do the comment I just made. And this
  • 00:25:29
    obviously wouldn't just necessarily be a task for ERCOT, but to
  • 00:25:33
    a degree, resources were, you know,
  • 00:25:35
    lag somehow in the model to be distinct. I don't know
  • 00:25:39
    that that makes it any easier to try to understand whether
  • 00:25:42
    or not the behavior was economic or not.
  • 00:25:46
    So. And I, you know, I will say also to
  • 00:25:50
    some degree, part of what I feel like we learned with 1030 is
  • 00:25:55
    we just. Where we landed
  • 00:25:59
    was to narrowly focus it on the problem at the time. And I.
  • 00:26:03
    Even before now we've implemented 1030, it's evolved into something that
  • 00:26:06
    needs to be revisited. So this seems warranted to
  • 00:26:09
    try to think a little bit further ahead than
  • 00:26:14
    necessarily just trying to deal with
  • 00:26:17
    what we think happens or potentially happens today.
  • 00:26:22
    Very helpful. Thanks, Dave. Thank you.
  • 00:26:26
    Steve Reedy, you're up. Yeah, I just wanted to bring
  • 00:26:33
    a little more light. I also was not
  • 00:26:36
    involved in the original decision
  • 00:26:41
    to base CARD off of the peak 15 minutes
  • 00:26:44
    settlement, but I can tell you that it really isn't a
  • 00:26:48
    nodal concept. That's something that was in place for the zonal
  • 00:26:52
    distribution of TCR revenue. So that's. It's just
  • 00:26:56
    a very. It's something that the market
  • 00:26:59
    came up with. A very long time ago,
  • 00:27:02
    and I think it's very reasonable to
  • 00:27:07
    relook at it. The market's changed significantly in the last
  • 00:27:10
    20 years.
  • 00:27:14
    Thank you for that, Steve, very helpful. Sean, you're up.
  • 00:27:21
    Yeah, I just wanted to give a little history on this.
  • 00:27:24
    So Rainbow Energy actually pointed
  • 00:27:28
    out this problem with allocation based on the
  • 00:27:32
    peak and the perverse incentive, that sense,
  • 00:27:36
    way back in 2017.
  • 00:27:39
    And the solution we proposed back
  • 00:27:43
    then is to offset all the market distorting
  • 00:27:49
    allocation of fixed costs, sunk cost,
  • 00:27:53
    the other one of course, being the transmission TCOS allocation.
  • 00:27:57
    So what we propose at that time is to actually allocate it
  • 00:28:01
    on the same basis as TCOS so that there's no,
  • 00:28:05
    you know, so that minimizes the perverse incentive with chasing
  • 00:28:09
    TCOS as well. If you do
  • 00:28:12
    that, then, you know, right now, TCOS the
  • 00:28:16
    summer peak hours. Those could be even negative price
  • 00:28:20
    hours, and you have load curtailing in those negative price hours, which means
  • 00:28:24
    you're curtailing even more renewables,
  • 00:28:27
    which doesn't make sense as to why load should be responding to
  • 00:28:31
    that price signal and resulting
  • 00:28:36
    in more loss of renewables.
  • 00:28:39
    One of the options we could consider is actually allocating it in
  • 00:28:43
    the same, consistent with the TCOS allocations. The net
  • 00:28:47
    of the two almost nets out. So you won't have
  • 00:28:50
    any allocation of fixed costs that will distort market price signals.
  • 00:28:55
    So something to consider. And we brought this up way back in
  • 00:28:59
    2017, this issue with perverse incentives in the market.
  • 00:29:03
    Thanks, Sean, real quick,
  • 00:29:06
    what was the result of that? Did it get withdrawn
  • 00:29:09
    or was it. What happened?
  • 00:29:13
    So basically, I guess in
  • 00:29:16
    NPRR1030 we actually suggested that all loads should be
  • 00:29:20
    allocated the same way. But what happened was,
  • 00:29:23
    I guess NPRR1030 was approved the way it is currently.
  • 00:29:27
    Okay, so it was in NPRR1030 that that
  • 00:29:31
    was identified? Yes, as well as
  • 00:29:36
    POC project. We brought it up even before the NPRR1030
  • 00:29:40
    discussion. Thanks, that's helpful. Thank you.
  • 00:29:43
    Next we have Ken Lindbergh from Bryan,
  • 00:29:47
    your question is in the key, but you want to restate that for the group.
  • 00:29:58
    You may be having audio issues, but the preferred option, does it only
  • 00:30:02
    apply to DC Ties or does it apply to everyone, is the question.
  • 00:30:08
    Yeah, I'm on now. Oh, go ahead,
  • 00:30:11
    Ken. Yeah. And so I'm just. I must
  • 00:30:14
    have missed it. But, yeah. Does the preferred option only
  • 00:30:18
    apply to DC Ties or does it apply to everyone?
  • 00:30:22
    It would apply to all load. You know,
  • 00:30:29
    I would be concerned that we're just swapping one inefficiency
  • 00:30:32
    for another. And so you're fixing DC Ties, but it seems like
  • 00:30:36
    for some large loads, like maybe crypto
  • 00:30:40
    miners or data centers who
  • 00:30:45
    like respond to 4CP over the summer.
  • 00:30:49
    And so their 15 minutes interval, there's.
  • 00:30:53
    They're missing 4CPs. They're not getting. They're lowering
  • 00:30:56
    their TCOS that they pay.
  • 00:30:59
    But then if we move it to this, you know,
  • 00:31:02
    because there's such large loads over the course of the month, they end up even
  • 00:31:05
    getting more,
  • 00:31:09
    you know, share of the CARD,
  • 00:31:12
    which, you know, I know there's nothing we can do about the
  • 00:31:16
    TCOS allocation. That's a PUCT thing. But I. I don't know.
  • 00:31:20
    This seems like we're fixing one problem and maybe making a bigger problem.
  • 00:31:25
    Unless I misunderstand the 15 minutes allocation
  • 00:31:29
    of the
  • 00:31:33
    CARD currently. Ken, I'm sorry, this is just
  • 00:31:36
    to be. I guess, just to be clear,
  • 00:31:42
    as it stands, with what was approved with NPRR1030,
  • 00:31:45
    we were only changing it to use a monthly ratio share
  • 00:31:49
    for DC Ties. That was the compromise we mentioned in some of
  • 00:31:52
    the earlier slides.
  • 00:31:55
    As we now think about the potential behavior of loads
  • 00:31:59
    that are much more flexible, the idea is to revisit
  • 00:32:03
    that and do something else for everyone.
  • 00:32:06
    And again, our preferred option is to do a monthly load ratio share
  • 00:32:10
    for everyone. And then there's a couple of alternates that are
  • 00:32:13
    sort of somewhere in the spectrum between a full monthly load ratio share
  • 00:32:17
    and something more akin to what we have with peak today.
  • 00:32:21
    And I think the idea is let's make
  • 00:32:24
    it, let's remove some of the perhaps
  • 00:32:29
    perverse incentive and make it such that you can't
  • 00:32:32
    just respond to 115 minutes interval and,
  • 00:32:36
    you know, which has probably fairly minimal economic impact.
  • 00:32:40
    And this is actually some of the useful data that, that Andrew
  • 00:32:43
    will walk through on some of the ways they've been thinking about it. But if,
  • 00:32:48
    if you only have the economic impact of responding to 115
  • 00:32:52
    minutes interval, it may be very well in your best,
  • 00:32:57
    best economics, or however you want to describe it,
  • 00:33:00
    to increase consumption,
  • 00:33:04
    even if it's not economic in the real time market, to maximize
  • 00:33:08
    those auction revenue distribution. So how can we spread that out
  • 00:33:11
    across more periods of time? And again, that can be. Again,
  • 00:33:15
    our preferred is to spread across the whole month. So it really is very
  • 00:33:19
    unlikely to change consumption behavior at all. And there's
  • 00:33:23
    some things in between that and what we have today with just the
  • 00:33:26
    single 15 minutes interval. Okay, let me just make sure I got
  • 00:33:30
    the history right. So I have the. So the
  • 00:33:35
    CARD was for everyone distributed
  • 00:33:39
    on a, like a monthly
  • 00:33:42
    load share ratio. At some
  • 00:33:46
    point in time, we changed that for,
  • 00:33:50
    for DC Ties. And now we're relooking at that.
  • 00:33:55
    Correct. It's in fact. In fact, 1030 is not technically
  • 00:33:58
    implemented, but. Right. It's based on the peak interval and
  • 00:34:03
    has historically been based just on the peak interval of the month. And it
  • 00:34:06
    sounds like, from Steve, back into pre, pre nodal days,
  • 00:34:11
    we had, under 1030, we changed that just for DC
  • 00:34:15
    Tie exports to make that more spread across the month. Now, this is
  • 00:34:18
    talking about spreading across the month in some form or fashion, with these
  • 00:34:22
    three options for everyone.
  • 00:34:26
    And. Okay, and so,
  • 00:34:30
    all right, and so this,
  • 00:34:34
    your preferred option for everyone,
  • 00:34:42
    means that 4CP
  • 00:34:47
    responders will
  • 00:34:52
    avoid TCOS, but then on the back end
  • 00:34:55
    of the CARD allocation,
  • 00:35:01
    they will, you know, they will be
  • 00:35:05
    paid on a monthly load share ratio.
  • 00:35:10
    Yes, I think. And I guess within our proposal, there's there is really no
  • 00:35:14
    linkage to TCOS allocation. I think shams was talking about
  • 00:35:18
    what Rainbow had proposed a couple of years back when we were talking
  • 00:35:22
    about this, but there's cost allocation,
  • 00:35:26
    and very distinctly under the proposal,
  • 00:35:29
    it's simply a monthly load ratio share determines
  • 00:35:33
    for each month what your distribution of the CR
  • 00:35:36
    ox revenues will be. So I'm
  • 00:35:40
    going to just reiterate my point and just
  • 00:35:45
    make sure I understand this. So if we change this
  • 00:35:49
    for everyone with the ERCOT
  • 00:35:53
    proposed solution,
  • 00:35:57
    we will have large loads, like,
  • 00:36:01
    let's just use crypto miners,
  • 00:36:05
    who some of them avoid 4CP,
  • 00:36:08
    and so they don't pay very much TCOS.
  • 00:36:13
    And right now, since it's
  • 00:36:16
    on a 15 minutes basis, at least on some of the
  • 00:36:21
    months, they're not receiving a whole bunch of CARD because
  • 00:36:25
    they're the same 15 minutes, they're avoiding,
  • 00:36:28
    to avoid TCOS, end up getting avoided in
  • 00:36:33
    the cardinal. And so,
  • 00:36:37
    with this change, using a crypto
  • 00:36:41
    miner as an example, they can avoid TCOS
  • 00:36:46
    in the four summer months,
  • 00:36:50
    and then still in
  • 00:36:54
    those corresponding months, get payments,
  • 00:36:59
    you know, way greater payments with this new methodology,
  • 00:37:03
    because it's on a megawatt hour instead
  • 00:37:07
    of a peak method.
  • 00:37:16
    Yes, I guess I think the word. So for.
  • 00:37:19
    Specifically for the summons that
  • 00:37:22
    apply for TCOS allocation, I think that that's a
  • 00:37:25
    fair point. This would probably more be a concern for the
  • 00:37:30
    sort of the rest of the year and months,
  • 00:37:35
    where essentially you can,
  • 00:37:38
    by responding within 115 minutes interval or changing your behavior
  • 00:37:42
    for 115 minutes interval, and particularly if TCOS aren't applicable
  • 00:37:45
    for that month, you can maximize your auction revenues without really
  • 00:37:49
    having any cost to bear, very minimal cost to bear relative to their
  • 00:37:53
    increased distribution. So this would be, I would say, more concerning,
  • 00:37:57
    probably for the other months of the year that
  • 00:38:01
    are outside the summer months for TCOS allocation.
  • 00:38:05
    And so Im going to stop talking here a second. And so thats
  • 00:38:08
    my point is Im concerned that we might be fixing
  • 00:38:13
    a DC Tie problem to just make
  • 00:38:19
    an even bigger crypto miner, you know,
  • 00:38:23
    large load avoiding TCOS problem. Anyways,
  • 00:38:26
    thank you. Well, and I'm sorry if I can just one thing.
  • 00:38:29
    One, I wanted to note that part of the point
  • 00:38:33
    of the presentation here and discussion here is that it's not just a DC type
  • 00:38:37
    problem. This is now belief that
  • 00:38:40
    is a more broad issue than that, with actual loads
  • 00:38:44
    that are flexible and can change their consumption. Maybe another
  • 00:38:48
    just distinction I want people to think about is,
  • 00:38:52
    I think the concern we more broadly want to address is,
  • 00:38:56
    to the degree more and more of our load now becomes
  • 00:39:00
    controllable, where they can increase in consumption.
  • 00:39:03
    We want to minimize incentives, for example,
  • 00:39:06
    car distribution, for people to increase
  • 00:39:10
    their consumption during peak intervals.
  • 00:39:13
    And with this proposal, effectively,
  • 00:39:17
    there is no sort of useful behavior you could do because it's looking across
  • 00:39:21
    the whole of the month where you should be able to
  • 00:39:25
    change behavior to increase
  • 00:39:28
    your CARD revenues. And again, I know Andrew put a comment in
  • 00:39:32
    the chat here. I think his presentation would be very helpful
  • 00:39:36
    for doing that. One distinction I
  • 00:39:39
    would just make, though, from what. From what you're describing, is,
  • 00:39:44
    yes, these resources that are avoiding TCOS will
  • 00:39:48
    potentially get some share of the CR auction revenues,
  • 00:39:52
    but they can't necessarily change their behavior to
  • 00:39:56
    maximize CRR option revenue unless they're increasing their consumption across
  • 00:40:00
    the whole of the month. And that. That's more of the point, but I'll stop
  • 00:40:03
    there. And it would probably timely to turn it over
  • 00:40:07
    to Andrew. Yeah.
  • 00:40:11
    Sean, is it okay if we. If we let Andrew present,
  • 00:40:14
    or do you want to add something about ERCOT's proposal? Yeah, no,
  • 00:40:17
    I'd like to add something right now, because this discussion is exactly
  • 00:40:22
    the point we were making back seven years ago, which is
  • 00:40:26
    that, you know, if you do this, change what ERCOT is proposing
  • 00:40:29
    here, and Ken, I think, said it perfectly,
  • 00:40:33
    you, misalignment again, you're creating another issue.
  • 00:40:37
    So, at least for the summer months, keep it based
  • 00:40:41
    on the peak hours. At least you're
  • 00:40:44
    offsetting that bad incentive
  • 00:40:47
    of chasing 4CP and getting the auction revenues.
  • 00:40:52
    Our proposal was put all the money of Sierra auction revenues to offset
  • 00:40:56
    the 4CP, so that in that case, you're reducing
  • 00:41:00
    the incentive to even chase 4CP,
  • 00:41:04
    because that really doesn't benefit the market. And we've seen that during
  • 00:41:07
    4CP hours, you'll see negative prices pretty soon, if not already.
  • 00:41:12
    So it doesn't make sense to have these loads
  • 00:41:17
    responding and reducing load when the prices are already negative.
  • 00:41:21
    So if nothing, all CARD revenues being
  • 00:41:26
    paid on the 4CP, then at least the summer months paid
  • 00:41:29
    on the 4CP and the other months do it on the monthly load ratio
  • 00:41:33
    share. Thanks. Thank you.
  • 00:41:36
    Okay, let's go ahead and turn it to Andrew and
  • 00:41:41
    let him give his presentation and we'll see what WMS wants to do
  • 00:41:46
    next steps. Thank you.
  • 00:41:49
    Thank you. Good morning everybody. Let me get my slides
  • 00:41:54
    up here. Oh, there they are already. Do you
  • 00:41:58
    all see my slides? Am I seeing the same thing you are?
  • 00:42:01
    Yes. Okay, great.
  • 00:42:04
    And am I in the driver's seat? I am.
  • Item 5.3 - IMM CARD Analysis - Andrew Reimers
    00:42:07
    Okay. We've already gone over a lot of this stuff, so I
  • 00:42:11
    will be quick with some of the background here. We all know what CARD is.
  • 00:42:15
    I think Dave and Randy at all. Did a good
  • 00:42:19
    job of kind of giving the, our best understanding of
  • 00:42:22
    the history of it and the justification for why it was designed the way
  • 00:42:26
    it was. But we have reason to believe that the conditions
  • 00:42:30
    that justified the previous,
  • 00:42:37
    the current CARD methodology are
  • 00:42:40
    not necessarily true and that they create some
  • 00:42:45
    adverse incentives for load behavior. So if
  • 00:42:49
    we go ahead to the next slide,
  • 00:42:55
    the long and short of our analysis is
  • 00:42:59
    that the window of time over which the
  • 00:43:03
    fard is calculated is the biggest
  • 00:43:06
    driver in the the
  • 00:43:13
    value that a load would have for trying to maximize their load ratio share.
  • 00:43:17
    So we already understand the hard payment
  • 00:43:21
    is a function of the load ratio share during some interval. Currently it's the
  • 00:43:24
    15 minutes coincident price interval, and that's
  • 00:43:28
    only 15 minutes. And so keep that in mind. And the longer
  • 00:43:33
    that interval is, that number tends to go down as far as the dollars
  • 00:43:37
    per megawatt hour that is being recovered over that time.
  • 00:43:41
    And so if we think about how this factors into a loads
  • 00:43:45
    operating behavior, essentially, if they have some
  • 00:43:48
    actual value for consuming electricity and then
  • 00:43:51
    they gather some revenue for CARD,
  • 00:43:55
    the sum of those things is going to determine their actual break
  • 00:43:58
    even price for that CARD interval. So in the example I give,
  • 00:44:03
    break evens for crypto miners currently are around $100
  • 00:44:07
    a megawatt hour. If for some months and in some zone,
  • 00:44:11
    the CARD revenue over some period of time equates to $1,000
  • 00:44:15
    per megawatt hour. Then over that interval the
  • 00:44:18
    load is economical at $1,100 a megawatt hour, which is obviously
  • 00:44:22
    many times higher than their actual breakeven price
  • 00:44:26
    based on the value of the energy they're consuming. So they're now,
  • 00:44:30
    inflating demand, potentially driving up prices,
  • 00:44:33
    this is exactly the situation that we want to avoid. So if we go
  • 00:44:37
    to the next slide, my summary of
  • 00:44:41
    how these different distribution
  • 00:44:45
    methodologies pencil out the current peak interval
  • 00:44:49
    methodology, depending on which zone you are operating in,
  • 00:44:52
    corresponds to thousands of dollars of per
  • 00:44:56
    megawatt hour of revenue opportunity. And it's actually
  • 00:45:00
    on the order of maybe $15,000 a megawatt hour out
  • 00:45:04
    west. So it is a very substantial revenue
  • 00:45:08
    opportunity for loads. If you have a lot of these crypto loads, like say
  • 00:45:11
    you have these less efficient crypto loads that are older, whose breakeven
  • 00:45:15
    price might only be dollar 20 a megawatt hour or something
  • 00:45:18
    like that, it would make perfect economic sense
  • 00:45:22
    to try to ramp these things up during the CARD window because
  • 00:45:26
    you're just earning so much more money for maximizing your
  • 00:45:29
    load ratio share. The peak day alternative
  • 00:45:33
    does significantly reduce this incentive,
  • 00:45:37
    but it's still a pretty high number. So for the
  • 00:45:40
    peak day, we're looking at a value of something like $100
  • 00:45:44
    a megawatt hour in value associated with CARD.
  • 00:45:47
    So, you know, much less than $16,000,
  • 00:45:50
    but still pretty high, especially when we're considering loads
  • 00:45:53
    that their actual value is on the order of $100 a megawatt hour.
  • 00:45:57
    If we look at this over the whole month, we end
  • 00:46:01
    up with a value for CARD that's less than $10 a megawatt hour. And like
  • 00:46:04
    Dave was trying to say, we can talk more about
  • 00:46:08
    the 4CP stuff. IMM has alternative proposals
  • 00:46:12
    for 4CP already.
  • 00:46:16
    The point Dave was trying to make,
  • 00:46:18
    the offsetting 4CP points notwithstanding,
  • 00:46:22
    is that if you're only earning a few dollars a megawatt hour in CARD
  • 00:46:25
    revenue, there's really very little incentive to maximize your load
  • 00:46:29
    ratio share to try to capture that CARD revenue. You're not going to try to
  • 00:46:32
    consume electricity when it's dollar 20 more expensive
  • 00:46:36
    than your breakeven price, just so you can capture dollar four on
  • 00:46:39
    the back end. And so it really forces loads to stick
  • 00:46:43
    to their actual economics to a much greater degree than any of
  • 00:46:46
    these other concepts. And so
  • 00:46:49
    if we go ahead here, I have included
  • 00:46:53
    a slide that kind of walks through the math here.
  • 00:46:57
    I appreciate Randy sharing a spreadsheet that's probably
  • 00:47:00
    going to be more useful for everyone. But this is just to give you a
  • 00:47:04
    flavor of how I went about calculating these numbers.
  • 00:47:08
    All you need to do this, I'm assuming. Let's just
  • 00:47:12
    imagine we plunk a 1 load into
  • 00:47:15
    one of these load zones so you can kind of get a
  • 00:47:18
    normalized idea of how much dollars per megawatt can
  • 00:47:23
    be recovered from CARD. You need the
  • 00:47:26
    system load, the zonal load, the system CARD value,
  • 00:47:30
    the zonal CARD value, and then
  • 00:47:33
    with all of that, you can calculate the load ratio shares what
  • 00:47:37
    that comes out to in dollars per megawatt.
  • 00:47:40
    And then the main trick here is that if
  • 00:47:44
    you perfectly timed, when you're maximizing your
  • 00:47:47
    load ratio share to coincide with the interval over which CARD is
  • 00:47:51
    calculated, that's only a quarter of an hour. So you're dividing this
  • 00:47:55
    dollar per megawatt number by a quarter of an hour,
  • 00:47:59
    and you end up with this very, very high price of what the CARD
  • 00:48:02
    revenue is worth if you're able to capture it like
  • 00:48:06
    that. So this is for October 2023,
  • 00:48:09
    west load zone. You could repeat this exercise with
  • 00:48:13
    a peak day exercise. So it would be October 4,
  • 00:48:16
    2023, but using the whole day's load ratio share. So you're
  • 00:48:20
    going to get slightly different numbers. You're going to change this quarter of an
  • 00:48:23
    hour to 24 hours. That would be kind of the process
  • 00:48:27
    you would go through. And if you do that for the whole year, you can
  • 00:48:30
    get a table like I've produced for the next slide.
  • 00:48:40
    So this is essentially the summary of what the
  • 00:48:44
    CARD value has equated to, on average, for March
  • 00:48:48
    2023 to March 2024,
  • 00:48:52
    weighted averages and everything for each zone,
  • 00:48:56
    for each distribution methodology. So,
  • 00:48:59
    obviously, peak interval, that's what we have today.
  • 00:49:02
    That's much more concerning than anything else, particularly the south
  • 00:49:06
    and west. Those prices are so much higher, mainly as a function
  • 00:49:10
    of a, there's more congestion rate within those zones.
  • 00:49:13
    And so the, the zonal congestion distribution
  • 00:49:17
    number is very high. And then particularly out west, the load
  • 00:49:21
    is so low that it's easier to have a higher load
  • 00:49:24
    ratio share. The native load out west might only be ten
  • 00:49:28
    gigawatts. And so if you start building hundreds of megawatts,
  • 00:49:32
    gigawatt scale loads, they naturally are
  • 00:49:35
    a bigger part of the load ratio share. So,
  • 00:49:39
    like I said, peak day, massive improvement.
  • 00:49:42
    But 100, $200 a megawatt hour
  • 00:49:46
    of value for trying to chase CARD is still plenty of
  • 00:49:49
    incentive to operate in otherwise uneconomical
  • 00:49:52
    situations. And, you know, to kind of loop back to the 4CP
  • 00:49:56
    point. It's already a little harder to try
  • 00:49:59
    to capture CARD in summer months because
  • 00:50:04
    the prices are higher. And so if you're thinking about March,
  • 00:50:08
    the price on average might only be $30 a megawatt hour. If you're capturing $200
  • 00:50:13
    a megawatt of CARD revenue, anything that you
  • 00:50:17
    have is likely to be economical to run during those intervals,
  • 00:50:20
    even if it's something very inefficient. That has a $20 per megawatt hour breakeven
  • 00:50:24
    price. Thats a little harder in the summer, particularly if we have a year
  • 00:50:28
    like last year, where there were a lot of summer days where the prices were
  • 00:50:32
    in the thousands of dollars. This is less of an issue in the Houston
  • 00:50:36
    load zone than it is in the west load zone. Theres a
  • 00:50:40
    lot that could be said there, but you can see that if we switch to
  • 00:50:43
    the whole month, were really minimizing
  • 00:50:48
    the opportunities for loads to try to maximize
  • 00:50:52
    their consumption so that their recovering more CARD revenue.
  • 00:50:57
    Most important caveat here is that, again, these assume
  • 00:51:01
    that a load is perfectly able to overlap its consumption
  • 00:51:05
    with the CARD interval. And it's a pretty straightforward
  • 00:51:09
    way to think about if they had to operate
  • 00:51:14
    over a longer period of time to make sure that they captured CARD, that's going
  • 00:51:17
    to reduce the dollar per megawatt hour value. So if they had to operate for
  • 00:51:21
    a whole hour to capture the peak interval,
  • 00:51:24
    that equates to dividing this number by four.
  • 00:51:28
    So that would only be $4,000 per megawatt hour of value,
  • 00:51:32
    for example, peak day. If they actually end up
  • 00:51:35
    running for two whole days because they thought a day earlier
  • 00:51:39
    in the month would be the peak day, but then it turns out to be
  • 00:51:41
    a day later in the month, then this value could be dollar 95,
  • 00:51:44
    a megawatt hour, dollar 60, a megawatt hour, something like that.
  • 00:51:48
    But I think it's worth pointing out that those are still pretty high
  • 00:51:51
    prices, given how price is clear in this market in
  • 00:51:55
    general. And so the whole month numbers are just way lower
  • 00:51:59
    in terms of how much incentive a load would have
  • 00:52:03
    to maximize its load ratio share. So if it isn't clear already,
  • 00:52:07
    we favor ERCOT's preferred solution, which is to
  • 00:52:11
    divvy this up over the whole month, like we're already doing for DC Ties.
  • 00:52:15
    We don't really see a strong argument in favor of the peak
  • 00:52:19
    day alternative,
  • 00:52:22
    and I think the points about 4CP are interesting
  • 00:52:25
    and worth thinking about. But I would fall
  • 00:52:29
    back on. We already have arguments for an alternative to
  • 00:52:33
    4CP, and so I'm not really going to die
  • 00:52:38
    on the hill of defending the current 4CP arrangement.
  • 00:52:41
    So that's all I have, and I
  • 00:52:44
    think we could continue with questions if anybody has
  • 00:52:48
    any.
  • 00:52:51
    Looks like shams does very good. Yeah. Let's go back to
  • 00:52:55
    Sean's, and then we'll go to David Shams. Go ahead.
  • 00:52:58
    Yeah, the poor CP is not going to be easy to change
  • 00:53:02
    and something that's embedded in our
  • 00:53:05
    system, and a lot of people are responding to that and
  • 00:53:09
    stuff, but this is under our control. How we allocate
  • 00:53:12
    Sierra auction revenues. And just as a reminder,
  • 00:53:17
    doctors Hogan and Pope, in their report of how to
  • 00:53:20
    improve, what are the priorities to improve in
  • 00:53:24
    the ERCOT market? They identified these transmission investment cost
  • 00:53:28
    recovery as distorting the market as well as
  • 00:53:31
    the doctor Patton, you know, the IMM pointed
  • 00:53:36
    out that these kind of. Let me see his exact
  • 00:53:40
    quote. Allocating sunk costs based on real time
  • 00:53:44
    supply or demand can impact the efficiency of real time
  • 00:53:48
    markets. So these are allocation of sunk costs
  • 00:53:53
    for CP. So at least for the summer months, we shouldn't
  • 00:53:56
    move away from allocating on peak,
  • 00:54:00
    because you're just making it worse. You're making the 4CPA a stronger signal,
  • 00:54:04
    which is resulting in market distortions.
  • 00:54:07
    And you're allowing, as Ken pointed out, you're allowing people to recover
  • 00:54:11
    the Sierra option, at least for the summer months, keep it on the peak hours.
  • 00:54:15
    The 4CP sort of allocation, if not for the whole year,
  • 00:54:19
    all of Sierra auction revenues should be based
  • 00:54:22
    on the 4CP allocation. Then you would be sort
  • 00:54:26
    of mitigating the impacts of 4CP. And the fact
  • 00:54:30
    that 2023 had higher prices during 4CP hours.
  • 00:54:34
    Going forward, with all this solar being added,
  • 00:54:37
    you won't see that it's not peak hours that's going to matter
  • 00:54:41
    at all, it's going to be the net peak hours. So you
  • 00:54:45
    might even have negative prices during peak hours.
  • 00:54:48
    Right?
  • 00:54:53
    I would. Okay, someone needs to mute something.
  • 00:55:03
    Okay, I want to grant
  • 00:55:07
    part of your point. Okay. And then make a different point.
  • 00:55:13
    You're suggesting that if you distributed CARD
  • 00:55:17
    on the basis of 4CP load ratio share for the whole year,
  • 00:55:21
    so now for the whole year, all of the CARD revenue that
  • 00:55:26
    would be distributed back to load should be based on the 4CP
  • 00:55:29
    load ratio share. And then it kind of offsets the
  • 00:55:33
    transmission costs and addresses some of the negative
  • 00:55:40
    incentives created by 4CP as far as loads
  • 00:55:44
    that are able to avoid those costs. That's correct,
  • 00:55:47
    yes. Okay. That is an interesting point, and I would have to think
  • 00:55:50
    more about that. What I want to kind of just point out, as far
  • 00:55:54
    as making the problem worse,
  • 00:55:59
    you're right that on the margin, it makes it even more attractive
  • 00:56:02
    to avoid 4CP. Because right now there is a
  • 00:56:06
    net cost to avoiding 4CP that is offset somewhat by the fact that
  • 00:56:10
    if you were operating during 4CP, you would be capturing some CARD revenue.
  • 00:56:14
    And so the cost of 4CP is somewhat less than it would be.
  • 00:56:18
    Okay. Whoever is doing that needs to be muted. I don't
  • 00:56:22
    understand what's happening, but. So,
  • 00:56:26
    looking at it, the cost of 4CP is still just way higher than the
  • 00:56:29
    value of CARD. And so you might split the difference
  • 00:56:33
    a little bit by not having the CARD interval calculated at the same
  • 00:56:36
    time as the 4CP interval. But right now, it isn't really economical
  • 00:56:40
    for anyone to operate during a 4CP interval just to capture cardinal.
  • 00:56:44
    So it's a literally correct point, but maybe
  • 00:56:48
    not a particularly important
  • 00:56:53
    point, because it's already. 4CP is so much more expensive than CARD
  • 00:56:56
    is valuable. So just wants to make that point. But why
  • 00:57:00
    make the price signal even stronger? I mean, why not keep the summer months,
  • 00:57:03
    at least the summer months, based on the peaks,
  • 00:57:07
    the force VP peaks? So, in that case,
  • 00:57:10
    you're not making the situation worse. I'm just going to have a hard
  • 00:57:14
    time advocating for that whenever we already have kind of an alternative
  • 00:57:18
    proposal for transmission cost allocation.
  • 00:57:21
    So. Right. Until that is, I mean,
  • 00:57:24
    I just think 4CP is so embedded, it's going to be very difficult to
  • 00:57:27
    change that. But we've been trying to change 4CP for a long time now.
  • 00:57:30
    But I'm saying that, you know, this is an opportunity, and if 4CP
  • 00:57:34
    changes, yeah, we can change it to a different allocation monthly
  • 00:57:38
    for all months, based on monthly load ratio share.
  • 00:57:41
    But for now, at least, for the summer months, let's keep it 4CP.
  • 00:57:45
    And for the other months, do the monthly load ratio
  • 00:57:49
    share. That would be. Well, is that what you're proposing,
  • 00:57:53
    or the way you had proposed it?
  • 00:57:57
    Okay, that's one option. Or your other option was use
  • 00:58:01
    the 4CP load ratio share for the whole year, and then
  • 00:58:05
    I. Instead of doing any monthly load ratio shares.
  • 00:58:08
    Yeah, that would be the ideal. Okay.
  • 00:58:12
    So I'm providing two options. Yeah. Yeah.
  • 00:58:15
    Okay, that's kind of interesting.
  • 00:58:18
    I'll have to think more about that. So, thanks.
  • 00:58:24
    Okay, next up, Bob Widmyer.
  • 00:58:30
    I think David Key is before me. Oh,
  • 00:58:33
    I'm sorry. I misread it, David. I'm sorry. Yes, go ahead.
  • 00:58:37
    No worries. Thank you. Good discussion. And it's knocked
  • 00:58:41
    some cobwebs loose, I believe. So. I believe
  • 00:58:44
    the IMM and ERCOT are focusing, really, on rational
  • 00:58:48
    market outcomes. And I don't want to speak to any of that, but I do
  • 00:58:51
    want to raise an observation, and it was somewhat discussed
  • 00:58:55
    around, I think, by Ken and others, on really, what the CARD is intended
  • 00:58:59
    to do. I feel like I heard,
  • 00:59:02
    maybe it wasn't what I heard, but I think what I remember what
  • 00:59:06
    we've understood the CARD to be is something is more of a type of refund
  • 00:59:10
    for transmission ratepayers. That's why TCOF comes into it.
  • 00:59:14
    I think the concern that I'm hearing, and maybe it's not being
  • 00:59:18
    fully understood or considered, is just the bigger policy issue
  • 00:59:22
    that if you're avoiding tcos, you're not really a transmission rate payer,
  • 00:59:26
    but you're still getting this refund. It's more of a bigger policy
  • 00:59:29
    issue to consider for loads that avoid
  • 00:59:33
    transmission costs but still get a refund in part of this CARD. So I
  • 00:59:38
    recognize that this is more of a, how are these,
  • 00:59:42
    how is the CARD able to be gained? But I'm not thinking about that for
  • 00:59:46
    what I'm just trying to raise as an observation. I'm thinking more of the general
  • 00:59:48
    application of the CARD and how it's appropriate
  • 00:59:52
    based on the intention of that refund of the money.
  • 00:59:56
    So that's the observation I wanted to raise. Not really a question, just something for
  • 01:00:00
    us to think about on the bigger level. Thank you.
  • 01:00:03
    Thank you, David. Thank you. Okay, Bob,
  • 01:00:06
    kind of along Dave's comments there on thinking about the
  • 01:00:10
    bigger picture sure seems to me,
  • 01:00:13
    regardless of the month, let's just exclude 4CP
  • 01:00:17
    months for the moment. We should not be sending incentives
  • 01:00:21
    to load to increase their on peak
  • 01:00:24
    load ratio share. That, that is not what we want
  • 01:00:28
    to do. We want the load more level rather than peaky.
  • 01:00:32
    So anything we do that contributes to more people
  • 01:00:35
    wanting to increase their peak, that seems
  • 01:00:39
    in the opposite direction of what we want to do. Thanks.
  • 01:00:45
    Okay, Dave, you want to jump in or do you want, want me to go
  • 01:00:48
    to Blake? I'm happy
  • 01:00:52
    to wait. Thank you. Go ahead, Blake. Blake,
  • 01:00:55
    halt. Go ahead,
  • 01:01:03
    Blake Holt. Yes, sir. Blake Holt,
  • 01:01:06
    lcRa. I know we're planning on discussing this next month as
  • 01:01:10
    well, but I wanted to get our initial opinions out here for the group.
  • 01:01:14
    You know, I agree a lot with what Bob just brought up.
  • 01:01:17
    You know, it's frustrating that potential bad behavior of a few
  • 01:01:20
    is going to disrupt a construct that's been
  • 01:01:23
    around for many years. But to Bob's point,
  • 01:01:27
    we would prefer option one or the daily load ratio
  • 01:01:31
    share of the peak interval day. We think it's long enough that it might disrupt
  • 01:01:35
    some of this behavior, and it would also be less disruptive to the
  • 01:01:39
    current allocation approach that was designed to for native
  • 01:01:43
    or existing loads around the peak day.
  • 01:01:46
    Alternatively, as we mentioned earlier, I think
  • 01:01:50
    we would probably be supportive of figuring out a way to figure out how to
  • 01:01:54
    split out these flexible loads and treat those on a monthly allocation
  • 01:01:58
    similar to the 1030 approach for DC Tie.
  • 01:02:02
    And then I guess just on the hybrid approach,
  • 01:02:05
    we think that's probably too complex for us to
  • 01:02:08
    support. Thanks.
  • 01:02:11
    Thank you, Blake. Okay, Dave. Yeah,
  • 01:02:15
    thank you. I just wanted to emphasize the point and it
  • 01:02:18
    ties very well to what Bob was sharing. You know, part of the
  • 01:02:21
    way I've been thinking about this as we've been having these discussions
  • 01:02:25
    is for a lot of the cases
  • 01:02:29
    and 4CP is an example of this.
  • 01:02:32
    In assigning a cost to load,
  • 01:02:36
    I. There is a desire to do it in such a way
  • 01:02:40
    to drive some desired behavioral,
  • 01:02:44
    desired behavior, I guess is the better way to say it in
  • 01:02:47
    the case where it's dollars being distributed too
  • 01:02:51
    low. As I think more about this,
  • 01:02:55
    it doesn't make as much sense to me that
  • 01:02:59
    we want to drive any behavior
  • 01:03:03
    that incents people to increase load, certainly not at peak,
  • 01:03:07
    whether or not we wanted to do it kind of the
  • 01:03:11
    peak of every day or whatever the case may be.
  • 01:03:15
    I'm just thinking about those differently between a.
  • 01:03:18
    When it's dollar is flowing too low based on a load ratio
  • 01:03:21
    share versus cost assigned to load on some
  • 01:03:25
    form of load ratio share basis. And to degree we want to use both
  • 01:03:29
    of those desire. Maybe there's a distinction there that needs
  • 01:03:33
    to be drawn and that we can think about and talk more about as we
  • 01:03:37
    continue this conversation. So again, maybe just, also just
  • 01:03:40
    the last note, the again, really, this, this was
  • 01:03:44
    the kickoff, the conversation to have folks start thinking about
  • 01:03:48
    it for folks who have been thinking about to share their opinions. And hopefully
  • 01:03:53
    we have now another month to kind of come back and see where
  • 01:03:57
    the WMS membership is thinking about
  • 01:04:00
    and where they may want to go at the August meeting. So thank you all
  • 01:04:03
    for the time today. Yeah, thank you, Dave. I think
  • 01:04:06
    that's a good wrap to this discussion. I thought it was really helpful
  • 01:04:10
    to get the history and understanding and sort of
  • 01:04:14
    trying to lay out all the different alternatives. So it
  • 01:04:19
    looks like, you know, this was exactly what you were looking for.
  • 01:04:22
    I want to encourage everyone to continue thinking
  • 01:04:26
    about this and let's come back next month realizing
  • 01:04:30
    that this is just leading to an NPRR that will be
  • 01:04:33
    filed, that will go through all this probably all over again.
  • 01:04:36
    But I do know that ERCOT would like to propose
  • 01:04:39
    something that's consistent with what WMS would endorse.
  • 01:04:43
    So let's bring that back next month.
  • 01:04:46
    And if you have additional information,
  • 01:04:49
    Dave or Andrew that you all want to present, maybe we can
  • 01:04:53
    have an update on any other discussions that you've
  • 01:04:56
    had next month. That's okay.
  • 01:04:59
    Yeah, sounds good to me. Thanks, guys. Okay. Thank you so
  • 01:05:02
    much.
  • 01:05:05
    Okay. We are right on schedule, I believe, with our agenda,
  • 01:05:09
    which is good news and bad news. Our agenda goes kind
  • 01:05:12
    of long today, but we'll keep moving forward with
  • 01:05:16
    report template to track AS provision and performance issues
  • 01:05:20
    related to insufficient state of charge. We have Luis Hinojosa
  • 01:05:24
    and Sam fabricant to
  • 01:05:29
    provide the presentation. Thank you. This is Luis.
  • 01:05:32
    Can you hear me? Yes, sir. Thank you. Appreciate it.
  • Item 5.4 - Report template to track AS Provision & Performance issues related to insufficient State of Charge<br />Luis Hinojosa & Sam Fabricant
    01:05:36
    Okay, as mentioned, if we can go to slide two here.
  • 01:05:40
    So this report here, this is a template
  • 01:05:44
    that we are proposing on
  • 01:05:49
    sharing some information that was requested of us. So the background here is we
  • 01:05:54
    have NPRR1186 that was recently implemented on
  • 01:05:58
    June 27. And what this brought was our ability to account
  • 01:06:03
    for state of charge better. We've brought several discussions on this
  • 01:06:07
    to our working groups, but now EMS
  • 01:06:10
    is now calculating, you know, managing our SCid
  • 01:06:14
    dispatch based on the amount of state of charge and that that's needed to support
  • 01:06:18
    ancillary service obligation. Now,
  • 01:06:21
    additionally, with NPRR1186 and NPRR1149,
  • 01:06:24
    as they were approved, they do not take into account the
  • 01:06:28
    state of charge or any shortfall that may be there for any of the
  • 01:06:31
    ancillary service obligation. So this was a
  • 01:06:35
    request that we received from tax, indicating that maybe we, we would like to
  • 01:06:39
    see a monthly report that's tracking the AS shortfall
  • 01:06:42
    due to SOC. So again, this is the template that we've put together.
  • 01:06:47
    I will lead off with this is all mostly
  • 01:06:51
    mock data because NPRR1186 was not implemented as we were
  • 01:06:55
    working through this template. So if you see some
  • 01:06:59
    funny numbers, if you see things that don't align, that's just because we had to
  • 01:07:02
    put some data together to try to indicate what we wanted or had an
  • 01:07:05
    idea of a flavor of what we could show. So I just wanted to
  • 01:07:09
    make sure that that's clear. Now, as we get into
  • 01:07:13
    the two things that we wanted to show in this report is failure to
  • 01:07:17
    provide and failure to perform. So failure to provide
  • 01:07:20
    is you telemetered, you had a responsibility, but your state
  • 01:07:24
    of charge may show that you may not have had full capability for
  • 01:07:27
    that ancillary services. And today we
  • 01:07:30
    even will have hassle will be limited for dispatch when this
  • 01:07:34
    scenario happens.
  • 01:07:37
    Additionally, failure to perform is we had
  • 01:07:40
    an event on the system where we had a request
  • 01:07:43
    for dispatch and we did not see the energy bid be dispatched
  • 01:07:47
    for that. So as we get into slides three and four, three and four are
  • 01:07:50
    the ones that focus on failure to provide.
  • 01:07:55
    Well, 1 second, I'm sorry, let me. Can we go back to slide two?
  • 01:08:01
    Yeah, and I just wanted to clarify a few things here for what this megawatt
  • 01:08:05
    shortfall is. So the EMS is calculating a shortfall,
  • 01:08:09
    it's calculating a shortfall over the hour and
  • 01:08:13
    converting this to a megawatt shortfall. And what needs to be clear here is the
  • 01:08:17
    way we then take the hour leash megawatt shortfall
  • 01:08:20
    and we disperse that amongst the, as that the resources are carrying.
  • 01:08:24
    And we start with Non-Spin, we move to ECRS, RRS and regulation.
  • 01:08:28
    Um, if you're only carrying Non-Spin, it all goes to Non-Spin.
  • 01:08:31
    If you're not carrying a Non-Spin at all, it goes to ECRS and so
  • 01:08:34
    on and so forth, depending on how much shortfall there is.
  • 01:08:37
    Um, we also show the percentage of shortfall
  • 01:08:41
    for the hour, hourly, daily, um, or monthly
  • 01:08:44
    based on the charts that we've put together. And, and we've
  • 01:08:47
    also showed the as shortfall cost. So what was the market
  • 01:08:51
    clearing price for that ancillary service for that day? Um,
  • 01:08:55
    and how short did we come up from a cost perspective for
  • 01:08:59
    the month? One thing additionally is now that NPRR1186
  • 01:09:02
    is in production, we do plan to share a production version
  • 01:09:06
    of this starting in August, which would mean all of
  • 01:09:10
    July would be with NPRR1186 implemented,
  • 01:09:13
    showing a real data version of this report.
  • 01:09:16
    Okay, next slide.
  • 01:09:23
    Slide three, please. Okay, thank you.
  • 01:09:26
    Okay, so here this is more trying to, again, failure to
  • 01:09:30
    provide and going to a more monthly view.
  • 01:09:33
    Again, we're breaking up your megawatt, the megawatt shortfall for
  • 01:09:37
    the ancillary service obligation that we have, starting with Non-Spin ECRS
  • 01:09:40
    RS regulation. FFR is in here as well. I missed
  • 01:09:43
    this, but FFR is only looking at a
  • 01:09:48
    slightly different calculation. I'll leave that there's a clarification for failure to provide later
  • 01:09:52
    or perform. Now here we're
  • 01:09:55
    showing you megawatt short. We're showing you the ancillary service cost short. We can
  • 01:09:59
    show it by month. And we're
  • 01:10:02
    showing you megawatt short cost short. And then overall, how many hours short.
  • 01:10:06
    Now the hour short. The clarification here is this is by
  • 01:10:10
    month. You may see more hours in the month because this is based on each
  • 01:10:13
    individual ESR that was identified as being short. So it's the
  • 01:10:17
    number of hours short by ESR. One thing I will say
  • 01:10:21
    here is we're looking for feedback. If some of this doesn't make sense, if there's
  • 01:10:24
    something that somebody would like to see, we are asking to provide
  • 01:10:28
    us feedback and let us know if there's something that would be better beneficial
  • 01:10:31
    to sharing this information. The second point that I
  • 01:10:35
    wanted to make here is we are also showing what
  • 01:10:39
    the language at NPRR1186,
  • 01:10:42
    if, if the proposed language would have been approved on
  • 01:10:45
    what that shortfall exceedance should be, if it's greater than two megawatt hour hours,
  • 01:10:49
    or the lower of eight megawatt hour hours, or 20% of the integral SOC requirement.
  • 01:10:53
    Complications there of the complexities there of what
  • 01:10:57
    that would mean. But again, that's what was proposed in NPRR1186.
  • 01:11:00
    Again, we're just showing you what it would have shown if that language
  • 01:11:03
    was approved. And then we intend
  • 01:11:07
    to put in some observations at the bottom based on as how we go through
  • 01:11:10
    the months. Okay, next slide here.
  • 01:11:19
    Now we're getting into more detailed data. Again,
  • 01:11:22
    still failure to perform, but this is now showing the same information,
  • 01:11:26
    looking at a specific day, looking at a specific hour, going into
  • 01:11:29
    box plots. Just again, just showing a flavor of what we can
  • 01:11:33
    do with the data we have.
  • 01:11:36
    We can simplify, we can make these more complicated,
  • 01:11:39
    but again, just looking for
  • 01:11:43
    feedback. This is a lot of the similar data that you saw in the last
  • 01:11:46
    slide, just more detailed. One thing that
  • 01:11:49
    I will say, again, this data may not correlate exactly to what you saw in
  • 01:11:53
    the last slides just because it was template data that we're trying to put together.
  • 01:11:59
    Next slide.
  • 01:12:07
    Now we get into failure to perform. And one of the metrics that
  • 01:12:11
    we're using here is looking at those resources that are carrying rrs that
  • 01:12:15
    have low SoC. We're using the ERCOT ballot
  • 01:12:19
    tre zero zero one logic that we share with
  • 01:12:22
    PDCWG to do primary frequency response performance evaluations.
  • 01:12:27
    We can do primary frequency response at 1% droop response. We can look
  • 01:12:31
    at FFR deployments. Here is the clarification I
  • 01:12:34
    wanted to share is FFR is just, did you provide your full capability
  • 01:12:38
    when you needed to? And the low SOC that we use for this
  • 01:12:41
    template was 20% of your SOC remaining, which means
  • 01:12:45
    whatever capability you have left in your state of charge for dispatch,
  • 01:12:50
    that number could be lower. The 20% is a variable that we have.
  • 01:12:53
    We can make this 10%, we can make it 5%. We're looking for feedback.
  • 01:12:57
    What's more realistic, what do others want to see? One thing I'll say is
  • 01:13:00
    this is just looking at state of charge, and if you pass or failed the
  • 01:13:03
    performance, it's our best way to indicate if
  • 01:13:06
    potentially low state of charge could have had an impact on your performance.
  • 01:13:12
    And next slide.
  • 01:13:18
    Here's another version of failure to perform. This is now
  • 01:13:21
    utilizing the GREDP and CLREDP metrics that are already being calculated on
  • 01:13:25
    a monthly basis. We then take that
  • 01:13:29
    data that's been provided for those reports,
  • 01:13:32
    again apply the low SOC logic, which right now is 20%,
  • 01:13:36
    and then we can identify any resources that have failed intervals for either of
  • 01:13:39
    these reports and provide that as a potential failure to
  • 01:13:43
    provide due to low SoC.
  • 01:13:48
    I see there's a question.
  • 01:13:55
    Yeah, we have a question in the queue from Danny Musher.
  • 01:13:58
    Hey, can you hear me okay? Yes, sir.
  • 01:14:02
    Okay. Yeah, I just.
  • 01:14:06
    You had said at the beginning of the presentation on the first
  • 01:14:09
    slide that failure to provide is when we're delivering an
  • 01:14:13
    ancillary service responsibility, but our state of charge may
  • 01:14:17
    or may not show that we had a full capability with
  • 01:14:21
    respect to that responsibility.
  • 01:14:24
    So I just wanted to clarify that that's not how failure to provide
  • 01:14:28
    is currently defined or how it's being measured.
  • 01:14:35
    Right. For instance, like, if an ESR has
  • 01:14:40
    a 100 megawatt ancillary service responsibility,
  • 01:14:43
    but has 50% state of charge,
  • 01:14:46
    that doesn't mean that they're failing to provide if they
  • 01:14:49
    have. If they're 100 megawatt HSL. Right.
  • 01:14:53
    One of the clarifications I put at the beginning of this was the way NPRR1186
  • 01:14:57
    was written and 1149 are written. You're right. Is as
  • 01:15:01
    approved. Failure to provide is. Are you limiting
  • 01:15:04
    your responsibility? NPRR1186 had
  • 01:15:08
    the logic. There some language in there for performance of.
  • 01:15:11
    Additionally, we should consider state of charge, which was
  • 01:15:15
    not approved, but which led to this request for this temp,
  • 01:15:18
    this report on what if we were looking at state of
  • 01:15:21
    charge, how much potential
  • 01:15:25
    for failure to provide? Do we see if we're looking at how much state of
  • 01:15:28
    charge is being. How state of charge is being managed based
  • 01:15:34
    on the NPRR1186 language that wasn't approved?
  • 01:15:38
    Correct. Okay. This was just. This was a request we received
  • 01:15:42
    indicating we would still like to see if state of charge leads
  • 01:15:46
    to any additional concerns.
  • 01:15:49
    Gotcha. Thank you for the clarification.
  • 01:15:52
    Sure. Thank you, Danny. Sean,
  • 01:15:55
    you're up? Yeah. On the failure
  • 01:16:00
    to maintain sufficient SoC. I guess that won't
  • 01:16:04
    be in any report or anything, but even the state
  • 01:16:08
    that in presentation is kind of problematic because there
  • 01:16:12
    is no failure, you know, currently,
  • 01:16:16
    for not maintaining. You could say, you know, like in these charts,
  • 01:16:20
    instead of short, megawatt short. Instead we could say insufficient SoC
  • 01:16:24
    or something like that. But it's not a failure according to the protocols.
  • 01:16:29
    Sure. I would just be cautious in the use of the terminal term failure
  • 01:16:32
    to maintain sufficient SoC. Okay.
  • 01:16:35
    Okay, thanks, shams and again, to clarify.
  • 01:16:38
    Yes, again, this is not
  • 01:16:42
    showing any, that there's no compliance language related to NPRR1186,
  • 01:16:46
    related to state of charge. This was, again, to fulfill a request that we received
  • 01:16:50
    from TAC. They would like to see how state of charge
  • 01:16:53
    could be impacting any of the ancillary service obligations that are out there.
  • 01:16:58
    And a follow up. So will this also, this reports also
  • 01:17:02
    include people that had sufficient state of charge but failed to
  • 01:17:06
    provide if you
  • 01:17:09
    had?
  • 01:17:12
    Yes. Well, I need to clarify that on this portion. I think we're
  • 01:17:16
    only looking at low SoC. Had you
  • 01:17:20
    failed and had more than 20, this what
  • 01:17:23
    we say, 20% low SoC, it may not directly be included in here,
  • 01:17:27
    but we could probably adjust to include that. I know it'll
  • 01:17:30
    be in our normal reports that we post everywhere else for GREDP and CLREDP,
  • 01:17:33
    ADP. So I think that's why we excluded it from here.
  • 01:17:37
    Okay. Yeah, it might be good to include it so that we see how
  • 01:17:41
    much actually the impact of batteries are failing anyway,
  • 01:17:45
    whether SOC had anything to do with. Thanks. I will say
  • 01:17:48
    shams. We do cover that already in PDCWG,
  • 01:17:53
    and there is a GREDP report that's also posted for PDC
  • 01:17:57
    as well, related to those that have failed these metrics.
  • 01:18:02
    Okay, thanks. Thank you,
  • 01:18:05
    Sean. Bob, you're up. Yeah. Just for clarity,
  • 01:18:09
    we are looking here at individual Reese,
  • 01:18:12
    individual esrs, not a portfolio
  • 01:18:15
    of esrs. Correct. So it's not that the.
  • 01:18:18
    It's not the QSE failed. It is the QSE
  • 01:18:23
    had a resource that could not provide.
  • 01:18:27
    Not that the QSE could not provide. Is that the right
  • 01:18:30
    way to look at this? That is correct. But we have the ability to
  • 01:18:34
    identify which QSEs have the largest failures in
  • 01:18:37
    their portfolio. Oh, that's fine. But you're not
  • 01:18:41
    saying that any QSE failed in any of
  • 01:18:45
    these slides. You're simply saying the esrs
  • 01:18:49
    within the portfolio failed, but not that the portfolio failed.
  • 01:18:53
    So it would be both. The performance is at the unit
  • 01:18:57
    level, but we can view it all the way up to QSE to say
  • 01:19:00
    the QSE is in its portfolio, filled. I think we even have
  • 01:19:04
    an appendix slide showing that we can look at this at QSE level.
  • 01:19:08
    Okay, that's good. Thank you.
  • 01:19:13
    Okay, any other questions for
  • 01:19:17
    Luis? Any comments, anything you
  • 01:19:20
    need from us, Luis, at this moment, or did you. Yeah, what you need if
  • 01:19:24
    you go to the next slide? I just summarize everything we just said. We covered
  • 01:19:27
    everything. Oh, I'm sorry. No, no problem. Okay. And we'll have
  • 01:19:30
    another comment from Michael. Yeah, go ahead. Yeah, I just wanted to say again,
  • 01:19:34
    we plan to make an official august report with July data
  • 01:19:37
    now that we have everything in production. We're also sharing this template
  • 01:19:41
    with WMWG and TAC later this month. But the request for
  • 01:19:45
    everybody is if you have feedback, anything else that wasn't mentioned today,
  • 01:19:48
    after you have more time to review this, please send me any feedback,
  • 01:19:52
    and we'll work through making adjustments on anything that we feel fits
  • 01:19:55
    with the report. That's it.
  • 01:19:59
    Very good. We have two more in the queue now. Caitlin Smith,
  • 01:20:03
    go ahead.
  • 01:20:08
    Hey, Eric. Thanks. Can you hear me? Yes, ma'am.
  • 01:20:12
    Okay, I have probably a lot of
  • 01:20:15
    questions, but I'll narrow it down for the group.
  • 01:20:19
    So I think Danny was getting to this, but we're a
  • 01:20:23
    little bit confused on the
  • 01:20:27
    slide three. On the version that was posted,
  • 01:20:31
    there's some notes, but we're kind of. I think it's unclear how
  • 01:20:35
    you're calculating the shortfall because you have a megawatt
  • 01:20:39
    short calculation that says shortfall over time remaining the hour,
  • 01:20:43
    and then an integrated short that says integration of megawatt
  • 01:20:46
    short across all hours. So I think we'd like
  • 01:20:50
    to see some numbers to an example there. It seems like maybe
  • 01:20:53
    the intent would be for less of a requirement as you go on
  • 01:20:57
    in the hour and go on in time, but I'm not sure that's
  • 01:21:01
    what those values are saying, so I'd like to see some examples there.
  • 01:21:06
    And then, you know, it seems like maybe we're conflating,
  • 01:21:10
    like, every reason there is a as shortfall.
  • 01:21:14
    I don't think they're all due to SoC. I think there can
  • 01:21:18
    be, you know, unplanned equipment issues like every technology
  • 01:21:21
    has. And I think to Bob
  • 01:21:25
    Whitmire's point, right, what every other resource
  • 01:21:29
    gets is the failure at the QSE level. The QSE has the opportunity
  • 01:21:34
    to provide the ancillary service. And so I really just want
  • 01:21:37
    to make sure this is technology neutral to look individually
  • 01:21:41
    every resource for one technology type and say,
  • 01:21:44
    you know, any shortfall that could affect another resource is
  • 01:21:48
    this SOC failure, I think is a little bit misleading.
  • 01:21:52
    And then on slide four,
  • 01:21:57
    I know you talked a little bit about kind of scrambling to put this together
  • 01:22:01
    and picking the days. I think we're just confused on
  • 01:22:05
    what this is trying to show, especially with
  • 01:22:10
    the dollar amounts. It seems like this is a little
  • 01:22:13
    bit misleading and maybe just kind of trying
  • 01:22:17
    to show that there's this dollar amount of money that consumers
  • 01:22:21
    aren't getting. But I don't think that that is what this is actually
  • 01:22:25
    showing. Right. I think you don't necessarily correlate
  • 01:22:28
    high prices with ancillary service need or
  • 01:22:31
    performance. And then you can't kind of like anything else.
  • 01:22:35
    You can't look at it in a vacuum. Right. You can't just say,
  • 01:22:38
    like, ancillary service money, what wouldn't have been there, we wouldn't
  • 01:22:42
    have spent it. Like, the trade off when you are managing your SoC
  • 01:22:46
    is probably higher energy prices later.
  • 01:22:49
    So I think we're really confused, especially to the cost
  • 01:22:53
    of what this is trying to show. It seems kind of misleading
  • 01:22:57
    to say that, you know, somebody's not getting what they're paying for,
  • 01:23:00
    but I don't think that this is showing that.
  • 01:23:05
    Okay, Caitlin, this is Luis. I'll try to TAC some of
  • 01:23:09
    the responses here. Yeah. And we can talk offline,
  • 01:23:12
    especially that request for kind of walking through the number of examples.
  • 01:23:16
    Yeah, I think the walking through the numbers is probably better. Something we can
  • 01:23:19
    share with WMWG. We can get into the details there.
  • 01:23:22
    We'll try to add some examples into the slides to kind of correlate that,
  • 01:23:26
    because it does get pretty confusing as to how we calculate
  • 01:23:29
    the integral and, you know, things like that. So I think that's something we can
  • 01:23:32
    add for WMWG.
  • 01:23:35
    Okay. Thank you,
  • 01:23:38
    Caitlin. Anything? Did you want to respond to any other
  • 01:23:42
    comments now, or do you want to hold those for WMWG? We'll hold for WMWG.
  • 01:23:47
    Okay, very good. Michael Jewell,
  • 01:23:50
    you're up. Thanks. Eric, can you hear me?
  • 01:23:54
    Yes, sir. Thanks.
  • 01:23:57
    I think Caitlin raised a lot of really good questions, and I
  • 01:24:00
    think it kind of highlights, you know, as I was looking at
  • 01:24:04
    this, it feels like this is a report
  • 01:24:08
    that is implementing NPRR1186 as it
  • 01:24:11
    was rejected by the commission. I mean, is that a correct way of
  • 01:24:15
    looking at this,
  • 01:24:20
    Luis, other than the fact that there's not an enforcement, but all the words
  • 01:24:23
    are there as if it was being enforced in
  • 01:24:26
    a form of NPRR1186 is rejected by the commission.
  • 01:24:32
    So. Okay. May I, may I take this one?
  • 01:24:36
    Sure. So, yeah, thank you.
  • 01:24:38
    Potentially, maybe. Let's see if this helps,
  • 01:24:42
    at least. As the discussions around
  • 01:24:45
    amending NPRR1186 continued, there was a request
  • 01:24:48
    made to us, I think, both by TAC and board,
  • 01:24:52
    to ensure we continue monitoring state of charge
  • 01:24:56
    provisions and how they may impact ancillary services.
  • 01:25:00
    So this template was our first attempt of putting
  • 01:25:04
    together analysis that could be used to inform the
  • 01:25:09
    stakeholders on that particular request.
  • 01:25:13
    Certainly in some cases where thresholds were required
  • 01:25:17
    to report, or we felt thresholds would be appropriate to report
  • 01:25:20
    the more egregious violations in
  • 01:25:24
    the analysis, we did pick up the language,
  • 01:25:28
    the thresholds that were in some of the discussions we were having around
  • 01:25:33
    compliance in NPRR1186, but we are happy to recalibrate.
  • 01:25:37
    The purpose of having this conversation and sharing the
  • 01:25:41
    information with you all is exactly so that we can weed
  • 01:25:45
    out analysis that will be responsive and provide information
  • 01:25:49
    to the stakeholders.
  • 01:25:52
    Awesome. Okay. No, thank you, Nick. I appreciate it. I just think that
  • 01:25:57
    the way that this came across, it really kind of
  • 01:26:01
    looks like it's an implementation of what the commission rejected.
  • 01:26:05
    And so that was one of the concerns. And we can. One other quick.
  • 01:26:09
    Sorry. As Luis mentioned, we are happy to talk more at WMWG and,
  • 01:26:13
    you know, read out better phrasing on the reporting.
  • 01:26:17
    Awesome. No, thank you so much. One other quick question with
  • 01:26:20
    regard to slide five, the low
  • 01:26:24
    SOC limit, in thinking about the
  • 01:26:28
    way that NPRR1186, as rejected by the commission would
  • 01:26:32
    have worked, that it was set up to where
  • 01:26:35
    a resource that was performing its ancillary
  • 01:26:39
    service obligation could go all the way to a 0% state
  • 01:26:43
    of charge at the tail end of the hour. But this
  • 01:26:47
    would seem to essentially add an additional
  • 01:26:50
    20% of state of charge
  • 01:26:54
    above and beyond the zero, as was reflected in the
  • 01:26:58
    charts discussed during the NPRR1186 debate.
  • 01:27:02
    Yeah. So this one, this is just looking at anytime
  • 01:27:06
    your SOC is below 20% to see if you failed.
  • 01:27:10
    All we were trying to do is find an easier
  • 01:27:14
    way to identify anybody who's operating in that lower range.
  • 01:27:17
    So you're right, you could be all the way at 0% and pass, and you
  • 01:27:20
    would not show up in this report, or at least in this table on
  • 01:27:23
    slide five.
  • 01:27:27
    Okay. So it's not in addition to anything that
  • 01:27:30
    you have as a obligation, it's just wherever you're telemetering us now.
  • 01:27:34
    And any resource that performs well
  • 01:27:38
    would not show up here at any range of SOC.
  • 01:27:45
    Okay, I'll chew on that. Thank you. Sure.
  • 01:27:49
    Thank you, Michael. Bob Wittemeyer. If the goal
  • 01:27:52
    here is to report shortages of
  • 01:27:56
    ancillary services, seems to me
  • 01:27:59
    you need to at least include a slide that shows
  • 01:28:03
    the QSE, the number of QSEs that are short,
  • 01:28:08
    not just the. The ESR,
  • 01:28:12
    that is short. Again, the measure was ancillary
  • 01:28:16
    services short. You're not showing that here.
  • 01:28:20
    Thanks.
  • 01:28:23
    Thank you, Bob. Caitlin,
  • 01:28:26
    you're up. Yeah. Luis, can you
  • 01:28:31
    clarify what you just said to Michael? The.
  • 01:28:35
    That you're only shown if you failed, and otherwise
  • 01:28:39
    you're not on here regardless of SoC? Can I think.
  • 01:28:43
    I'm not understanding what you're saying that this is showing.
  • 01:28:46
    Okay, can we go to slide five, please, to make sure we're all looking
  • 01:28:50
    at the same thing here. So here,
  • 01:28:59
    if you failed for a frequency event
  • 01:29:04
    and your state of charge was below 20% and your telemeter
  • 01:29:08
    state of charge, then we
  • 01:29:11
    would show you as failed in this report as a.
  • 01:29:15
    This is our way of finding ways to identify resources that
  • 01:29:19
    are potentially failing due to low state of charge. Again, the 20%
  • 01:29:22
    could be 10%, could be 5%. This is just where we started the analysis for
  • 01:29:26
    the template. But this is not saying you need more than
  • 01:29:30
    some amount of SOC to provide response.
  • 01:29:35
    So the failure is based on performance during a frequency event
  • 01:29:39
    or performance during a frequency event, or the 20%.
  • 01:29:44
    This is during a frequency event based on the bowel tre
  • 01:29:47
    standard. Okay. Okay, that's helpful.
  • 01:29:51
    Thank you. Sure. And then I think that I
  • 01:29:55
    wanted to circle back to Bob here. I wanted to make sure.
  • 01:29:58
    So we are looking at ESR level, at least from a primary frequency
  • 01:30:02
    response performance. But for the other ancillary services
  • 01:30:05
    that you were carrying, again, we do have a QSE slide in
  • 01:30:10
    the appendix that we can move up into the
  • 01:30:13
    main deck. And I agree, it is the
  • 01:30:17
    QSEs provision that should be providing or that
  • 01:30:21
    is essentially falling short because of an ESR performance.
  • 01:30:25
    But the QSE also has the ability to move around as, and things
  • 01:30:28
    like that as their responsibility in making sure that they can provide it if
  • 01:30:32
    that happens. It wouldn't, you ended,
  • 01:30:35
    you would not show short if the QSE is moving
  • 01:30:39
    over around the responsibility as needed.
  • 01:30:46
    Okay, I see a question from shams. Okay, go back
  • 01:30:50
    to the queue. We have shams, you're up. Yeah.
  • 01:30:53
    On this calculation, instead of
  • 01:30:56
    using arbitrary percentage, why not use the linear
  • 01:31:00
    curve going down to zero, which was in NPRR1186
  • 01:31:07
    as a metric, as the parameter that you judge
  • 01:31:11
    whether you were short SOC or not?
  • 01:31:16
    You could, but that
  • 01:31:20
    wouldn't necessarily indicate.
  • 01:31:27
    Let me, let me think about that one, choms, and maybe we can pick this
  • 01:31:31
    one up next time. Okay. Because I think you're using
  • 01:31:34
    that calculation in the previous set of, you know,
  • 01:31:37
    whether we're short as whether you had insufficient SOC.
  • 01:31:41
    You're using that curve. Right. To determine whether you had
  • 01:31:44
    insufficient SOC. So I think you can use the same curve
  • 01:31:47
    to do this as well, because otherwise the 10%, 5% or
  • 01:31:52
    20% is sort of arbitrary sense.
  • 01:31:55
    Thanks.
  • 01:32:01
    Okay, next, Danny Musher, hero.
  • 01:32:04
    Hey, Louise, can you just remind me for the RSPFR,
  • 01:32:11
    if a ESR is carrying the
  • 01:32:14
    rs on the CLR, so you know it's
  • 01:32:18
    low on SOC, but it's carrying it on the CLR and
  • 01:32:22
    there's an event. How does that show up here?
  • 01:32:25
    Or what would. Would it be
  • 01:32:29
    captured as a low SOC ESR? Can you just explain what
  • 01:32:33
    would happen there? Sure. Again, this is still performance at
  • 01:32:37
    an ESR level. So long as your resource performs,
  • 01:32:43
    you will be marked as a pass. It doesn't.
  • 01:32:47
    Ideally we're carrying everything on the GR side, but as
  • 01:32:50
    you mentioned, there are scenario where there where you're low on state of charge.
  • 01:32:53
    So you would be below the 20% potentially if you had to move
  • 01:32:57
    it over. But if you performed well, you would not show
  • 01:33:01
    up on the list. If you failed, you would still be marked as a potential
  • 01:33:04
    failure due to low SOC,
  • 01:33:10
    regardless of where you're carrying your responsibility.
  • 01:33:16
    Okay, I see one more question and then I'm going to ask that we
  • 01:33:20
    hold off. We've already said we're going to discuss this
  • 01:33:23
    at WMWG. So, Sean, do you have another question?
  • 01:33:28
    Yeah. So I guess I was a little confused with the last answer.
  • 01:33:31
    So I was assuming that
  • 01:33:35
    even with your SOC insufficiency, that if you had a charging base
  • 01:33:38
    point, you would take that into account in determining whether you
  • 01:33:41
    had sufficient SOC or not. Sure you do.
  • 01:33:46
    You do. But I think similar to many
  • 01:33:49
    of the other conversations we've had today, I think if we can bring, add some
  • 01:33:52
    examples on the details of state of charge and expectations and calculations
  • 01:33:57
    that might help this discussion. So maybe we hold these for WMWG as
  • 01:34:01
    well. Okay. And that's even more reason why
  • 01:34:04
    we shouldn't use the 20%, because if you were charging, you know,
  • 01:34:07
    it's a different calculation altogether. Okay,
  • 01:34:11
    thanks. Thank you. Can we go to the last slide?
  • 01:34:14
    There's a question I wanted to ask you, Luis.
  • 01:34:18
    You have this going to WMS and then TAC.
  • 01:34:23
    Or maybe not the last slide, but the summary page, I think was slide seven.
  • 01:34:30
    He showed it going to WMS, then TAC.
  • 01:34:34
    I'm curious, are you trying to hit the
  • 01:34:37
    august board? I'm curious why we wouldn't
  • 01:34:41
    go come back through WMS before we went up to TAC.
  • 01:34:46
    Typically, that's the way we do it. I just wondered, is there some timing reason
  • 01:34:50
    you're trying to get it to TAC on the 31st?
  • 01:34:56
    Yeah, we just wanted to make sure that we. So, because this
  • 01:35:00
    was a request for TAC, we wanted to ensure that we had it covered
  • 01:35:03
    through at least some of the working groups. And we wanted to target to make
  • 01:35:06
    sure we have some of these detailed discussions before we get to TAC.
  • 01:35:11
    Okay. We'll see what TAC does. With it. But we
  • 01:35:15
    might want to, I mean, depending on how it goes with WMS,
  • 01:35:18
    I might, you know, encourage it to,
  • 01:35:21
    you know, if there's a recommendation there that it could come through WMS
  • 01:35:25
    so that you get a WMS, you know,
  • 01:35:29
    review as well. But Caitlin, you have a comment or question.
  • 01:35:35
    Yeah, and I'm so sorry. I know you're trying to wrap this up, but it
  • 01:35:38
    was really, you know, you prolonged it with your own question.
  • 01:35:43
    Just for clarity. This is not right. We're not required
  • 01:35:47
    to do this. I don't think this has required approval.
  • 01:35:50
    And I'm trying to look back through my notes. I think that
  • 01:35:54
    this was a TAC request, but I
  • 01:35:57
    think it was maybe from one member or one segment.
  • 01:36:00
    And I believe it was raised even in commission discussion
  • 01:36:05
    when they were remanding
  • 01:36:08
    NPRR1186. So I think it would be good if,
  • 01:36:13
    you know, it can be me, but if somebody followed up on the intent there
  • 01:36:19
    and just getting that clarifying question
  • 01:36:22
    in there, too. This is not something that is required or needs
  • 01:36:26
    board approval or TAC approval or anything like that. I don't think it's on
  • 01:36:30
    a required timeline. And so I think it would be good if
  • 01:36:33
    we got sort of the commission intent,
  • 01:36:37
    especially since I think, as somebody pointed out,
  • 01:36:41
    it seems to kind of go to
  • 01:36:45
    enacting some of the things that were requested to be taken out
  • 01:36:49
    of the NPRR. That was my
  • 01:36:52
    question.
  • 01:37:00
    I guess it's just confirming that this doesn't need. This is not required
  • 01:37:03
    and doesn't need approval, and then
  • 01:37:07
    making sure somebody follows up on the intent of the
  • 01:37:11
    request that I believe maybe originated from the commission.
  • 01:37:19
    Yeah, I think that's definitely needed.
  • 01:37:23
    Okay. Sorry to open it back up, but we have some
  • 01:37:26
    in the queue. So, Michael Jewel, you have a comment? Yeah,
  • 01:37:30
    just. Just a quick comment. I think one of the issues that we ran into
  • 01:37:33
    in NPRR1186 is trying to move it forward very quickly without
  • 01:37:39
    time for folks to really be able to digest that.
  • 01:37:43
    I really would recommend, I totally appreciate that ERCOT
  • 01:37:47
    is trying to be responsive, to know,
  • 01:37:50
    to trying to report information that it feels like has been
  • 01:37:53
    asked for. But I think that it's also real important not
  • 01:37:57
    to rush this again and end up in a.
  • 01:38:00
    In a situation that's not helpful. Thank you,
  • 01:38:05
    Nevika. Actually, I was got in
  • 01:38:09
    queue to just reply back to Caitlin and Michael, hear your feedback,
  • 01:38:13
    and I think your memories on what Caitlin described is correct.
  • 01:38:16
    So we can take the action item of figuring out what our vehicle
  • 01:38:20
    for reporting this or responding to those requests would
  • 01:38:23
    be. And certainly we are looking to continue to
  • 01:38:26
    work with the stakeholders on developing the right template for
  • 01:38:30
    capturing this information. So we'll continue working on that
  • 01:38:34
    and bring back updates when we get to TAC as well on what we
  • 01:38:38
    found as far as procedure or process is concerned.
  • 01:38:43
    Very good. Thank you so much.
  • 01:38:47
    Let's move on. Unless someone else has something.
  • 01:38:51
    Let's move on to item number six, resource cost working group report.
  • 01:38:55
    Blake Holt.
  • Item 6.1 - RCWG Leadership - Vote - Blake Holt
    01:38:59
    Yes, sir. Thanks, Eric. Before we
  • 01:39:02
    get into the report, I wanted to bring an
  • Item 6.2 - Vice Chair - Kiran Sidhu, RWE
    01:39:06
    update to the group about leadership. The current vice chair,
  • 01:39:10
    Kieran Sidhu, has changed employers. He is now with
  • 01:39:14
    RWE renewables. I don't think he was
  • 01:39:17
    able to join us today, but I wanted to notify the group of the change
  • 01:39:20
    and see if we can add confirmation
  • 01:39:24
    of some support of his continued leadership to the combo ballot.
  • 01:39:30
    Thank you, Mister Gossip.
  • 01:39:33
    Very good. We will add that to the combo.
  • 01:39:36
    Thank you.
  • Item 6 - Resource Cost Working Group - RCWG - Blake Holt
    01:39:47
    Thanks, Brittany. So, just to update
  • 01:39:50
    the group, we met on June 25 to
  • 01:39:54
    continue discussion on VCMRR041.
  • 01:39:58
    And just for a refresher,
  • 01:40:01
    this one was submitted by ERCOT and it aims to eliminate
  • 01:40:05
    the current index price subscription for
  • 01:40:09
    NOx and SO2. And it would replace the subscription
  • 01:40:13
    with fixed prices for the products.
  • 01:40:16
    NOx would be $3, a short ton, and SO2 would
  • 01:40:19
    be $2, a short ton. And the justification for this,
  • 01:40:24
    from ERCOT's perspective is the annual index
  • 01:40:27
    pricing has remained stagnant over the last five years.
  • 01:40:31
    And their proposal is to keep
  • 01:40:35
    these fixed prices until either new EPA
  • 01:40:39
    requirements go into effect or ERCOT determines
  • 01:40:42
    that a competitive market exists for NOx
  • 01:40:46
    and SO2, or until TAC directs them otherwise.
  • 01:40:51
    Next slide. Hey,
  • 01:40:54
    is. Is this still under review at.
  • 01:40:57
    At the working group, or are you all. Have you completed your work?
  • 01:41:01
    It's still under review. I was going to go into the discussion that we got
  • 01:41:05
    into last month.
  • 01:41:08
    Okay. It will be coming back. And here's
  • 01:41:12
    you know, the conversation that went on.
  • 01:41:15
    Luminant has some interest in pursuing a seasonal
  • 01:41:19
    index price approach, which is historically higher,
  • 01:41:24
    may through September, and continue with the annual pricing
  • 01:41:28
    from January to April and October through
  • 01:41:32
    December. Illumina also mentioned seeing value in maintaining
  • 01:41:35
    the subscription to allow for a quick response to the political
  • 01:41:39
    landscape, and is considering proposing a user fee to
  • 01:41:43
    cover the cost of the subscription.
  • 01:41:46
    And Luminit also expressed that they're planning
  • 01:41:50
    on pursuing additional language, which would be incremental comments to
  • 01:41:53
    the VCMRR and a new NPRR to cover
  • 01:41:57
    the subscription piece. And my
  • 01:42:01
    understanding is that will be presented at the next July
  • 01:42:06
    RCWG. From the ERCOT perspective,
  • 01:42:09
    they cautioned that the new effort,
  • 01:42:12
    if it takes much longer to discuss, they may have to recommit
  • 01:42:16
    to the subscription for index pricing. And so
  • 01:42:20
    I put down a timeline for when I thought this could
  • 01:42:23
    potentially go through, and I've since been corrected that the
  • 01:42:28
    timeline is a little off. In fact, VCMRRs do not go
  • 01:42:32
    to PRS. They actually spend
  • 01:42:37
    two meetings at WMS for approval and
  • 01:42:41
    then would travel along the same timeline to the
  • 01:42:45
    September 25 tact October board and November
  • 01:42:49
    PUC meeting for approval. So if my
  • 01:42:53
    understanding is if we can get some consensus around the
  • 01:42:57
    new luminance version,
  • 01:43:00
    then we could potentially get it off approved
  • 01:43:05
    prior to the end of the year when ERCOT would be subject to the
  • 01:43:09
    new subscription price. But I'd like to pause
  • 01:43:12
    here and see if maybe Ino or Katie would like to correct anything I
  • 01:43:16
    have to say.
  • 01:43:21
    Yeah, Blake, this is Katie Rich with luminant. I was putting
  • 01:43:24
    things in the chat, but I think you largely have
  • 01:43:27
    this correct. So the NPRR would have to go through pknorthenne.
  • 01:43:31
    So while the VCMRR can be at WMS for
  • 01:43:35
    a couple of times, you're correct and your timing that
  • 01:43:38
    it would have to initially go and so my plan
  • 01:43:42
    is to have a draft filed in
  • 01:43:45
    advance of RCWG with a new VCMRR because
  • 01:43:49
    that was ERCOT's preference and the new NPRR and
  • 01:43:53
    then take the feedback from RCWG if
  • 01:43:57
    there is any, very quickly and I would have to get those filed
  • 01:44:00
    so that they can make WMS and
  • 01:44:04
    PRS for the dates that you have below. So just wanted to give people a
  • 01:44:08
    heads up of looking for that to be filed next week
  • 01:44:11
    in a quick turnaround time for incorporating any feedback from RCWG.
  • 01:44:25
    Eno, would you like to respond?
  • 01:44:28
    Well, not necessarily to what Katie was
  • 01:44:32
    stating, but more something that you said you
  • 01:44:36
    are correct about the timeline for moving along
  • 01:44:40
    the VCMRRs to the stakeholder process,
  • 01:44:42
    except they will go to PRS
  • 01:44:46
    if there's an impact. The VCMRR
  • 01:44:49
    zero four one as submitted by ERCOT has no impact,
  • 01:44:52
    therefore it was skip PRS, but it will stay at WMS
  • 01:44:56
    for two months, initial language approval or
  • 01:44:59
    review, and then for the impact analysis. Even though
  • 01:45:03
    there's no impact on the changes we propose.
  • 01:45:07
    Another caveat is it may not make
  • 01:45:11
    the November PUCT meeting. It all depends
  • 01:45:15
    on how fast or how soon ERCOT can
  • 01:45:18
    create the documentation from the board of directors to
  • 01:45:22
    send to PUCT. I do want
  • 01:45:25
    to point out though, for the entire WMS members
  • 01:45:30
    that you are correct, Blake, we have not seen any
  • 01:45:34
    trades for the annual price,
  • 01:45:38
    we are using only the annual price. We have not seen changes for
  • 01:45:43
    the last five years and the vendor told us there
  • 01:45:46
    are no trades. That's why we feel that a fixed price
  • 01:45:50
    is probably the best option right now for the annual price.
  • 01:45:54
    However, I also want to point out that the
  • 01:45:58
    vendor also told us there have not been any changes
  • 01:46:02
    or any trades for the seasonal price, which we're not
  • 01:46:06
    using currently. And the seasonal price between
  • 01:46:10
    May 1 and September 30 is around $700
  • 01:46:15
    per ton. But those prices are fixed as well right
  • 01:46:19
    now because of there's just no trades.
  • 01:46:23
    I also want to remind everyone that on
  • 01:46:27
    June 28, the US Supreme Court
  • 01:46:31
    stopped the implementation of EPA's
  • 01:46:35
    implementation of a good neighbor plan, which is basically
  • 01:46:39
    was trying to create require
  • 01:46:43
    additional control of NOx, and now
  • 01:46:46
    it sits at the lower court. So I don't, I'm not sure
  • 01:46:50
    how long before the EPA can implement any
  • 01:46:53
    changes to NOx and
  • 01:46:58
    whether or not we're going to have a market anytime soon. However, I assume
  • 01:47:03
    that if once, if he goes to the court system and
  • 01:47:07
    he gets approved, we should have enough time to
  • 01:47:10
    seek or choose a vendor. So as of
  • 01:47:15
    today, I'm still under the belief that is
  • 01:47:19
    better for everyone not to, for not to
  • 01:47:22
    spend additional money in a subscription.
  • 01:47:25
    And please keep in mind that this is an annual cost. This is not a
  • 01:47:29
    one time thing. It's an annual cost that the market is incurring
  • 01:47:33
    that we believe we should stop it until
  • 01:47:37
    such time that there's a market for emissions. However,
  • 01:47:40
    I recognize that luminance is proposing something else, and I'm
  • 01:47:45
    not going to comment on that yet, but I understand that's coming,
  • 01:47:56
    let's say. ERCOT. Yeah, I'll keep my comment brief
  • 01:48:00
    since I said it in the chat, but good idea. In the user
  • 01:48:04
    fee enos comments
  • 01:48:08
    about the lack of trading in this area.
  • 01:48:11
    This does make me concerned about using this index, and maybe if it's
  • 01:48:15
    not appropriate. And so I just appreciate
  • 01:48:19
    if the IMM can just take a look at this to see if they have
  • 01:48:22
    a recommendation as well to get a chance to
  • 01:48:26
    learn more about the liquidity in that market. Thanks.
  • 01:48:30
    Thank you, Katie. Yeah, I just wanted to
  • 01:48:34
    respond to what Ino was saying about trading, because I think that there
  • 01:48:37
    are two concepts here. So there's trading and
  • 01:48:41
    what causes scarcity pricing. So if we see
  • 01:48:45
    sort of a fair weather season, then the allowances
  • 01:48:49
    go down, so the prices go up in terms of scarcity.
  • 01:48:53
    And we can cite several examples. In fact, I've done that at RCWG
  • 01:48:57
    and I think WMS prior. So I just want to make sure
  • 01:49:01
    that folks aren't thinking about the trading. And while,
  • 01:49:04
    you know, the Supreme Court case had that particular ruling, you know, things could
  • 01:49:08
    still move quickly and having this concept
  • 01:49:12
    in place so that, you know, we could go back to,
  • 01:49:16
    you know, making changes based on trading. I think it's really important to keep this
  • 01:49:19
    in place. So just wanted to make sure folks were looking at that from.
  • 01:49:23
    From two different perspectives.
  • 01:49:29
    Okay. Thank you, Katie.
  • 01:49:32
    Blake. Anything else? The last update for the group
  • 01:49:35
    is our next meeting will be July 23,
  • 01:49:39
    and it will be a joint meeting with, actually a meeting occurring
  • 01:49:43
    immediately after WMWG, and we'll consider
  • 01:49:47
    and use the same WebEx information.
  • 01:49:51
    And that's all I have, Mister Blake. Great. Any questions
  • 01:49:54
    for Blake?
  • 01:49:57
    Okay, we are now just a little bit behind schedule.
  • Item 7 - WMS Revision Requests - Eric Blakey
    01:50:01
    Let's see if we can can get back ahead.
  • Item 7.2 - VCMRR040, Methodology for Calculating Fuel Adders for Coal-Fired Resources
    01:50:05
    We have WMS revision requests,
  • 01:50:08
    VCMRR040. This was
    EditCreate clip
  • Item 7.1 - Impact Analysis - Vote - Eric Blakey
    01:50:11
    one that we approved last month, the language. And today we're
  • 01:50:15
    voting on the impact analysis, which is zero impact.
  • 01:50:20
    And this is one that seems right for the
  • 01:50:23
    combo ballot. Is there any questions, discussion on
  • 01:50:27
    this proposal, this impact analysis, and putting this on the combo ballot?
  • 01:50:37
    Great. Thank you, Jim. We will add that to the combo ballot.
  • 01:50:41
    Next up, we have item number eight, the demand side working group
  • 01:50:45
    report from Nathaniel Mancha. Are you on the line?
  • 01:50:59
    Can you hear me now? There he is. Yes, go ahead.
  • 01:51:03
    Hello? Hi, Nathan. Can you
  • 01:51:06
    hear me?
  • 01:51:14
    Hello, Nathan.
  • 01:51:16
    Yeah, we hear you. Okay.
  • 01:51:20
    Sorry about that.
  • Item 8 - Demand Side Working Group - DSWG - Nathaniel Mancha
    01:51:26
    All right, so I'll be very. I'll be quick. So,
  • 01:51:37
    Nathan, yourself lost
  • 01:51:42
    you.
  • 01:52:04
    Is there any way we can unmute
  • 01:52:10
    his line or can we come back to him?
  • 01:52:13
    Can you hear me now? There he is. Yes, go ahead,
  • 01:52:16
    Nathan. Okay, sorry. I'm intermittently going back and
  • 01:52:20
    forth between connectivity today for some reason,
  • 01:52:23
    so I'll try to cover everything pretty quickly just to
  • 01:52:26
    make sure we get through stuff. So we went over goals, which was really
  • 01:52:30
    good for this team, since we kind of are on and off.
  • 01:52:34
    One of the big things we discussed during our meeting was the
  • 01:52:38
    various different meetings, like large flexible load.
  • 01:52:42
    They're discussing demand response a little bit in, like, technology groups and things
  • 01:52:46
    like that. So the ERCOT team and a
  • 01:52:49
    few of us said, hopefully we're going to try to do a little bit more
  • 01:52:53
    updates during the meeting of other meetings. Just because
  • 01:52:56
    a lot of us can't get to all of the meetings and with
  • 01:53:00
    the massive amount of just different focuses in
  • 01:53:03
    doctor, we just thought that it would be helpful for everyone, just so
  • 01:53:07
    we know which meetings to kind of go to different items
  • 01:53:10
    that we need to cover. So that, that was a really good part
  • 01:53:14
    of our meeting. So we discussed two different NPRRs
  • 01:53:18
    and I'll cover them. One of them was a presentation
  • 01:53:21
    NPRR1226 over the demand response monitor.
  • 01:53:25
    So this just actually, this item actually came up
  • 01:53:29
    in the large flexible load task force. Makes a lot of.
  • 01:53:34
    Makes kind of a lot of information kind of going back and
  • 01:53:37
    forth and gives the market a little bit more.
  • 01:53:41
    It publishes really what's going on from demand response standpoint
  • 01:53:47
    with not only the load that's being kind of curtailed, but also the
  • 01:53:50
    SCAD LMPs at the same time. So just
  • 01:53:54
    kind of going through this whole presentation,
  • 01:53:58
    the whole group really kind of liked this. This was something that
  • 01:54:01
    we really wanted to kind of take forward from
  • 01:54:05
    not only the demand side working group, but the large flexible load task
  • 01:54:09
    force. I mean, people have some questions about it that they can send them
  • 01:54:13
    to us and we can. We can talk more about it. This information
  • 01:54:17
    is some information from a
  • 01:54:21
    larger standpoint that ERCOT has already. We're trying to keep it
  • 01:54:25
    very. It was. It was kind of discussed to
  • 01:54:28
    keep the information more about zones,
  • 01:54:32
    how much load is coming off in the zones, and to be particular
  • 01:54:35
    about that, not about actual sites that are coming out so that people
  • 01:54:39
    can't kind of know who's coming offline.
  • 01:54:43
    But this is. This is going to be something that I think is going to
  • 01:54:46
    be discussed more and more as, you know,
  • 01:54:50
    things for. For CP and for just overall load shed
  • 01:54:54
    because of the numbers that we're coming out with. So,
  • 01:54:58
    next slide.
  • 01:55:02
    And then we also did discuss NPRR1217
  • 01:55:08
    So this is something big for the
  • 01:55:11
    whole market, because as this
  • 01:55:15
    gets approved and what this is, what this NPRR
  • 01:55:18
    is doing is it really. It removes the VDI
  • 01:55:22
    or the verbal dispatch instruction for load
  • 01:55:26
    resource and ERS deployments.
  • 01:55:29
    So a lot of the QSEs kind of should keep an eye on this,
  • 01:55:33
    especially because of how we digest the data that's coming in.
  • 01:55:37
    All of us, you know, to be very clear, all of us do get XML
  • 01:55:40
    files in order to deploy. It's just how to
  • 01:55:44
    take those XML files and basically pass on to
  • 01:55:48
    those that have clients that deal load rewards outside of just their
  • 01:55:52
    control areas. So this is something that is looking to
  • 01:55:56
    get implemented, like it says here, on December 1 of
  • 01:56:00
    this year, which is kind of coinciding with that, that final
  • 01:56:03
    ERS contract period that'll be going into
  • 01:56:07
    the following year. So this
  • 01:56:10
    will be something that, you know, we talked about. This is something that we would
  • 01:56:13
    want, as QSEs to probably get a little bit more testing in.
  • 01:56:17
    So as soon as we know that this is implemented at
  • 01:56:20
    that time period, which it should be, we kind of have to,
  • 01:56:24
    you know, dot I's and cross t's to make sure that we can deploy
  • 01:56:28
    using just without using VDIs.
  • 01:56:31
    Right. Which is a little bit of a change for some of us. So that's
  • 01:56:35
    my quick, skinny questions.
  • 01:56:41
    Okay, great report. Thank you. Any questions or comments
  • 01:56:44
    for Nathan? Nathan?
  • 01:56:49
    Okay, very good.
  • 01:56:52
    We'll go next. Item nine, which is the supply analysis working group.
  • 01:56:56
    Kevin Hanson, are you on the line?
  • 01:57:00
    Yes, sir. Brittany, if you can, please pull my slides.
  • 01:57:03
    Appreciate it.
  • 01:57:08
    As she's pulling them up.
  • 01:57:12
    Please appreciate it.
  • Item 9 - Supply Analysis Working Group - SAWG - Kevin Hanson
    01:57:15
    First item for discussion is the fact that
  • Item 9.2 - Chair Kevin Hanson, Black Mountain Energy Storage
    01:57:19
    I've changed employers going from national grid to Black Mountain
  • 01:57:23
    energy storage and requesting
  • 01:57:26
    a vote at WMS to approve that change. As we still remain
  • 01:57:30
    as chair,
  • 01:57:35
    we are very grateful to your service. Glad you're staying on it,
  • 01:57:38
    SAWG, and congratulations on your
  • Item 9.1 - SAWG Leadership - Vote
    01:57:42
    Black Mountain energy. Any comments
  • 01:57:45
    or concerns about confirming
  • 01:57:50
    Kevin as SAWG chair and putting
  • 01:57:53
    this on the combo ballot?
  • 01:57:58
    Yes, thank you very much, Kevin. I think we're
  • 01:58:02
    going to add this to the combo ballot. I'll let you proceed. Good. So if
  • 01:58:05
    we can move on to the next slide, please.
  • 01:58:09
    So. Already talked about point a there. So at
  • 01:58:13
    the meeting, we had a lot of good discussion. Analysis presented
  • 01:58:17
    from the staff at ERCOT. First, Dinesh presented
  • 01:58:22
    the annual distributive generation report.
  • 01:58:26
    What we saw for the 2023 annual estimate was approximately
  • 01:58:29
    48 mw, which includes around three gigawatts of less than
  • 01:58:32
    1 mw. Solar has been installed in the system by
  • 01:58:36
    2032. The moderate forecast is assuming approximately six gigawatts
  • 01:58:40
    of solar pv rooftop throughout ERCOT.
  • 01:58:44
    Next up, Katie Lamb and Sam Morris from ERCOT presented
  • 01:58:48
    on the updated long term load detailed
  • 01:58:53
    analysis. I encourage everybody to go through and look at, read the go
  • 01:58:57
    through the presentation for themselves. But some of the main points came from that
  • 01:59:00
    presentation was it assumes only cripple loads are dispatchable
  • 01:59:04
    in the load forecast data centers.
  • 01:59:09
    Data centers, hydrogen, ammonia, oil and gas industrial
  • 01:59:13
    manufacturing are assumed non dispatchable as they're represented by
  • 01:59:17
    24/7 loads.
  • 01:59:21
    Large flexible loads have a 50% response, which is tied
  • 01:59:25
    to 4CP. The ERCOT peak
  • 01:59:28
    from just 4CP impacts moves from hour 17 to our 2022 2028
  • 01:59:36
    slide. Twelve of their presentation shows that all new
  • 01:59:40
    contracted and executive letter LFL 100%
  • 01:59:47
    gigawatts.
  • 01:59:51
    And the other thing is the 2030 minimum load with all loads,
  • 01:59:54
    including the contracted executive letter LFLs
  • 01:59:58
    is around 88 gigawatts. And there's a question from Mister Yelven.
  • 02:00:06
    Thanks, Kevin. I appreciate you bringing that up. And apologies.
  • 02:00:10
    I couldn't make that meeting, but with respect to
  • 02:00:13
    that point you just made, was there any indication. And I'll go
  • 02:00:17
    through the presentation when I get a minute, but was there any indication of
  • 02:00:21
    the just under 148 gigs there,
  • 02:00:25
    of how much of that or what state in the process is that,
  • 02:00:29
    if. Or in other words, I guess, how do they define contract
  • 02:00:32
    in an executive letter? The concern I have is much
  • 02:00:36
    of this load is probably still speculative at this time,
  • 02:00:40
    and the messaging that this sends out with respect to
  • 02:00:44
    the market and market impacts can be kind of swayed
  • 02:00:48
    by the. By this kind of information. Was any of that discussed?
  • 02:00:51
    And can you answer that question? What they mean by new contracted and
  • 02:00:55
    executive letter? So, in the presentation, they showed essentially
  • 02:00:59
    going through what is,
  • 02:01:03
    you know, this new bucket here of
  • 02:01:07
    roughly, I believe it was roughly. I can't remember the number off top end,
  • 02:01:10
    but it's fair amount of load incorporated
  • 02:01:14
    in there. And it's still. I think it's
  • 02:01:18
    probably best to look at the large, flexible loads, their filings and
  • 02:01:22
    what they're showing as they're reviewing these large loads as
  • 02:01:26
    it moves forward from being. We'll call it speculative for
  • 02:01:29
    a term, till it becomes fully implemented by
  • 02:01:33
    ERCOT for their planning cases,
  • 02:01:38
    if any, for anybody. If ERCOT wants to address it further, they can.
  • 02:01:46
    Yeah, Kevin? Yeah, that's pretty much it. So, like,
  • 02:01:50
    when it comes to these contracts with.
  • 02:01:53
    With regards to LFL,
  • 02:01:56
    we kind of assume that they are contracted currently
  • 02:02:00
    as that, but that may be subject to change.
  • 02:02:04
    So we're treating them in the contract
  • 02:02:08
    and the officer letters, we're treating them
  • 02:02:12
    a little differently than we do in our.
  • 02:02:15
    In our regular forecast, where we would take them down to
  • 02:02:18
    the 50%.
  • 02:02:27
    I see Bob Witmeyer has a question next. Follow Jim for the follow up.
  • 02:02:33
    Yeah, on the two or
  • 02:02:37
    c? Two, how come we assumed hydrogen was a 24/7
  • 02:02:41
    load? All the indications we've had at LFL was they were
  • 02:02:44
    going to be flexible.
  • 02:02:49
    I'll take that again, cap. So, yeah, so this is Sam Morrison,
  • 02:02:53
    manager, load forecasting. The.
  • 02:02:57
    The issue with that is that that's not
  • 02:03:01
    proven yet. So we haven't seen any
  • 02:03:05
    type of profile or anything from anybody to say, yeah, this is what's
  • 02:03:08
    going to happen. Um, and kind of in the
  • 02:03:13
    e cig and larger conversations,
  • 02:03:15
    uh, what we're finding is that that
  • 02:03:19
    may be the case if they're planning, like, two or three days ahead to
  • 02:03:23
    be flexible. But in the real time,
  • 02:03:28
    due to different pressure requirements
  • 02:03:34
    and things coming off, trying to pull off the electrolyzers that quickly,
  • 02:03:40
    it becomes highly suspect that they would be
  • 02:03:43
    able to respond quickly. So in that
  • 02:03:46
    instance, we decided that it's best
  • 02:03:50
    to just treat them as 100% load, that they
  • 02:03:53
    have a very high load factor, and just keep it there for now
  • 02:03:57
    until we have a better understanding of what their profiles
  • 02:04:00
    are actually going to be.
  • 02:04:03
    Okay, I appreciate that, but we're going to spend tens of millions of dollars
  • 02:04:07
    if that assumption is wrong. Thanks.
  • 02:04:11
    Well, sir, I understand what you're saying,
  • 02:04:15
    but all indications of every hydro
  • 02:04:20
    that we have seen so far is that it's
  • 02:04:24
    not responsive. So that's
  • 02:04:27
    all we can go with. You know, think about
  • 02:04:30
    it. On the other end of things, if we said that it was,
  • 02:04:34
    it was responsive and it wasn't responsive, that becomes
  • 02:04:39
    a different problem, too. So, fair enough.
  • 02:04:41
    Thanks.
  • 02:04:45
    You have, Galvin.
  • 02:04:48
    That gets to my concern about,
  • 02:04:51
    about this, is that a lot of this is still very speculative.
  • 02:04:55
    Not just whether or not these loads will show
  • 02:04:59
    up, but what their true load factor will be.
  • 02:05:02
    And I guess, question, the real question is how does this, and when
  • 02:05:05
    will this manifest itself into the current load forecast that's
  • 02:05:09
    published? And I guess the planning
  • 02:05:12
    question is probably to stay tuned and get involved in that. But if you
  • 02:05:16
    just give me an idea of what is the plan to look at and how
  • 02:05:19
    we're going to change the long term load forecast, because that hasn't budged
  • 02:05:23
    since published at the first of the year.
  • 02:05:28
    So, yeah, we are planning on reposting this
  • 02:05:32
    with the new waterfalls for the contracts
  • 02:05:35
    and the officer letters there. That is,
  • 02:05:39
    we're hoping to have that done by the end of the month.
  • 02:05:44
    So basically, the goal
  • 02:05:47
    is next week, but just to make sure that we have enough time
  • 02:05:51
    for all the approvals, we're. We're saying
  • 02:05:54
    the end of the month.
  • 02:06:00
    Okay. Eric Schubert, you have a question? Yes. Can you hear me?
  • 02:06:03
    Sure. Yes. I'm a little
  • 02:06:07
    confused by the language here.
  • 02:06:10
    And that point to data centers, hydrogen, ammonia, oil and gas,
  • 02:06:14
    industrial manufacturing are assumed to be non dispatchable.
  • 02:06:18
    If you're talking about long term load forecasts, there is a difference
  • 02:06:22
    between responding in five minutes or ten minutes versus saying, I'm not
  • 02:06:25
    going to run this this afternoon because we're going to peak. And have
  • 02:06:29
    you distinguished with these particular industries the
  • 02:06:33
    difference between price response
  • 02:06:36
    in terms of anticipated high prices at a particular time versus a five
  • 02:06:40
    minute dispatch.
  • 02:06:45
    So we do not make any assumptions on
  • 02:06:48
    price and long term load forecasting. You know,
  • 02:06:52
    it's been known for years, for example, in the upstream oil and gas industry,
  • 02:06:56
    that there are some players who have, in the past,
  • 02:07:00
    responded to high prices during the summer by reducing pumping
  • 02:07:04
    at a particular time. So I think one thing you need to keep in
  • 02:07:08
    mind here is I understand this
  • 02:07:12
    group of industries are not necessarily price responsive
  • 02:07:15
    in terms of five minute skit, but where
  • 02:07:19
    you're talking about anticipated peak loads, which would possibly mean
  • 02:07:23
    high prices, you might want to keep in mind the fact
  • 02:07:26
    that there might be some peak shaving involved with at least some of those
  • 02:07:30
    industries. Yes,
  • 02:07:33
    in some instances, however,
  • 02:07:37
    if you kind of.
  • 02:07:40
    If you kind of take it down to the
  • 02:07:44
    profile or meter level, the consistency
  • 02:07:48
    of response is not there to
  • 02:07:54
    actually warrant us to say, yes, this is a responder.
  • 02:07:59
    Now, that's not to say that there is not some response already
  • 02:08:03
    kind of baked into the load forecast for a typical
  • 02:08:06
    4CP event, you know, typical 4CP
  • 02:08:09
    or near CP day. But to
  • 02:08:14
    try and focus in on, um,
  • 02:08:18
    kind of how one segment would
  • 02:08:22
    respond, there's a lot of these segments do
  • 02:08:25
    not respond very consistently,
  • 02:08:29
    say they don't. They don't respond, say, as. As consistent
  • 02:08:33
    as the steel mills would or other,
  • 02:08:36
    you know, other people. So there are some that
  • 02:08:40
    kind of follow that gray area of not necessarily
  • 02:08:44
    responsive, but they could respond if. If that's clear.
  • 02:08:48
    Makes sense.
  • 02:09:03
    Seeing other questions right now. I'm going to continue on.
  • 02:09:09
    So, next, after the load forecast discussion,
  • 02:09:12
    Pete Warkin provided an update on the cone study.
  • 02:09:16
    The cone study status report was filed at PUCT on June
  • 02:09:20
    6. The discussion of the cone study was held during the June 13
  • 02:09:24
    pct open meeting. The final report, the Cohen
  • 02:09:27
    model, has been completed.
  • 02:09:30
    ERCOT. It says after they have briefed the PUC that
  • 02:09:34
    ERCOT will be posting, location will be determined.
  • 02:09:37
    The other aspect is that from the report that I had,
  • 02:09:40
    was that the 10.35% at
  • 02:09:47
    Wack slide was.
  • 02:10:05
    Kevin, every once in a while you kind of break up and it just happened
  • 02:10:09
    again. Are you still there? Okay, still here. Can you hear me?
  • 02:10:15
    Hear me? Yeah. It just
  • 02:10:19
    breaks up randomly for some reason.
  • 02:10:23
    Brittany, next slide, please.
  • 02:10:32
    Next up, Pete discussed the reliability standard
  • 02:10:36
    update. With regards to that,
  • 02:10:38
    he's. Let's let the group know that the reliability
  • 02:10:42
    standard proposal for publication. Then it was
  • 02:10:45
    approved at the June 13 PUC open meeting.
  • 02:10:48
    The servo model data files are filed ERCOT website.
  • 02:10:52
    And I put in the link there. The important thing to remember
  • 02:10:56
    is that an account. You have to create an account in order to download the
  • 02:10:59
    files.
  • 02:11:03
    Next item was the volume update from Pete Warkin.
  • 02:11:07
    The Vaul survey was closed in May.
  • 02:11:12
    The Brattle project team is conducting a survey check and developing volume
  • 02:11:16
    estimation models. The preliminary
  • 02:11:20
    volume value based on survey data is expected in mid to
  • 02:11:24
    late July 2024.
  • 02:11:28
    Last item
  • 02:11:31
    discussed, or second to last item discussed was the August
  • 02:11:35
    Mora report. Q&A from Pete.
  • 02:11:39
    He mentioned that they added a low wind risk profile.
  • 02:11:44
    In addition to that, the monthly outlook includes a south IRL
  • 02:11:48
    impact in the analysis.
  • 02:11:51
    And finally the he
  • 02:11:54
    mentioned that the CDR NPRR is still being worked on.
  • 02:11:58
    That's it for SAWG.
  • 02:12:01
    Awesome. Thank you, Kevin. Any questions?
  • 02:12:05
    Seeing none. Let's move on to item ten,
  • 02:12:09
    which is the wholesale market working group. And again,
  • 02:12:13
    Blake Holt. We are starting
  • 02:12:17
    to pile up the work on Mister Holt.
  • Item 10 - Wholesale Market Working Group - WMWG - Blake Holt
    02:12:21
    Hi, Eric, this is Blake. Yeah,
  • Item 10.2 - Chair: Blake Holt, LCRA
    02:12:25
    Kevin alluded to he's switched employers
  • 02:12:28
    and I had an increased workload and needed
  • 02:12:32
    to step away from WMWG.
  • 02:12:35
    And the plan was if it's
  • 02:12:38
    the will of the group for me to step step forward into the chair position.
  • Item 10.3 - Vice Chair - Amanda Frazier, Treaty Oak Clean Energy
    02:12:42
    And then also Amanda Frazier has agreed to
  • 02:12:46
    help me out in the vice chair position and
  • 02:12:50
    just wanted to notify the group of that change of leadership
  • 02:12:54
    if it's amenable to the group.
  • 02:13:00
    I think it should be very excited to see
  • 02:13:04
    Amanda Fraser in leadership. One of my favorite people to ever work
  • 02:13:08
    with and just very grateful that
  • 02:13:12
    she's willing to step in. And thankful to you, Blake, for stepping up
  • 02:13:15
    to be the chair of this group. Very important group.
  • Item 10.1 - WMWG Leadership - Vote
    02:13:20
    And so I think it should be added to the combo ballot.
  • 02:13:23
    Is there any concern with that? Any questions?
  • 02:13:26
    If not, we will add that to the combo ballot. Did you have any other
  • 02:13:30
    report or is that it? No, sir. The group
  • 02:13:33
    did not meet last month, but we are planning on meeting on the 23rd.
  • 02:13:37
    I think the big item on the agenda
  • 02:13:41
    is the first review of the AS methodology from ERCOT,
  • 02:13:44
    but we should also have some other agenda items as well. So looking forward
  • 02:13:48
    to the conversation at end of the month. Thanks.
  • 02:13:51
    Yeah, very good. We have a comment from Caitlin.
  • 02:13:56
    Thanks, Eric. I just wanted to echo what you said.
  • 02:14:00
    Amanda said she might be interested and I remembered and jumped
  • 02:14:04
    on it. And I just wanted to say thank you to WMS
  • 02:14:08
    leadership as well. Eric and Jim, you can see from
  • 02:14:11
    today's combo ballot we are having to replace
  • 02:14:15
    lot of the working group leadership pretty
  • 02:14:19
    often, and that's been recurring all year. I think it's been a
  • 02:14:22
    good thing. We've had a lot of leaders return in different roles.
  • 02:14:26
    So I just wanted to say thanks to all those working group leaders,
  • 02:14:30
    and thanks to WMS leadership for their efforts there as well.
  • 02:14:35
    Thank you, Caitlin, for saying that. That's very kind. That is a
  • 02:14:39
    big role. I've learned WMS chair.
  • 02:14:42
    My main job is to seek and find replacements for
  • 02:14:47
    working group leadership. And so with that said,
  • 02:14:50
    anyone on the call who's interested in
  • 02:14:54
    working group leadership, please reach out to us, Caitlin, or me or Jim.
  • 02:14:59
    We are constantly looking for good folks, and we have a
  • 02:15:03
    great slate of working group leadership. I'm so grateful to them.
  • 02:15:08
    They're all very high quality, good leaders that
  • 02:15:12
    are doing the really big work of what WMS
  • 02:15:15
    does. So thank you. Next is
  • 02:15:19
    item eleven, metering working group. We had Michael Blum with CenterPoint,
  • 02:15:23
    but with the storm, he is
  • 02:15:27
    obviously doing better work,
  • 02:15:30
    probably with the restoration efforts. So we have Kyle Stuckley
  • 02:15:34
    filling in. Kyle, are you on the line?
  • 02:15:38
    Yes, Kyle Stucley with Oncor is. Is here.
  • Item 11 - Metering Working Group - MWG - Michael Blum
    02:15:42
    I did talk briefly to Mister Blum this morning.
  • 02:15:47
    No big concerns with this item. It's really
  • 02:15:50
    just a housekeeping and updating of the procedures.
  • Item 11.1 - Procedure Update - Vote
    02:15:57
    Okay. This is the procedure document that
  • 02:16:01
    goes on the working group website. Site hasn't
  • 02:16:05
    been reviewed since what, 2013?
  • 02:16:08
    Is that correct? Something like that.
  • 02:16:12
    Older? I got a 20. Oh 320.
  • 02:16:16
    Oh three. Okay. I was off with decade,
  • 02:16:19
    so I think it's high time to take a fresh look.
  • 02:16:23
    And I think the working group has done so.
  • 02:16:27
    And it was posted. Is there any comments or questions about
  • 02:16:31
    the change? Are we okay with approving
  • 02:16:35
    this today, or would we like to bring this back next month? What's the
  • 02:16:39
    will of the group?
  • 02:16:44
    Brittany Albright. Brittany? Yes. Hi.
  • 02:16:47
    Hi. Thank you. Just one
  • 02:16:50
    cleanup, I might suggest. You know, colloquially,
  • 02:16:54
    I think this has been called the metering working group.
  • 02:16:58
    I think that some overlap with the settlement metering
  • 02:17:02
    operating guide, when in fact, this has always been named the meter working group.
  • 02:17:08
    But down here in the language, a lot of the red lines say metering
  • 02:17:12
    working group instead of meter. And so
  • 02:17:16
    it's up to the meter working group if they want to change their
  • 02:17:19
    name to metering. But I would like it to be standardized either
  • 02:17:23
    one way or the other. And if
  • 02:17:27
    they're comfortable looking at this or discussing it again,
  • 02:17:30
    if it rises to that level, that is for y'all's consideration.
  • 02:17:38
    Yeah, I had noticed the same thing. And the website,
  • 02:17:42
    the ERCOT website, the head
  • 02:17:45
    group header is metering working group. And then it
  • 02:17:49
    starts out the meter working group and
  • 02:17:53
    its description. So it does need to be standardized one
  • 02:17:57
    way or the other.
  • 02:18:01
    And so, Kyle, we kind of probably leave it up
  • 02:18:04
    to you, though, to say whether you want to make that decision today
  • 02:18:07
    or do you want to hold off and we can bring this back next month,
  • 02:18:12
    I would suggest, given the weather, you know,
  • 02:18:16
    as in the storm restoration,
  • 02:18:20
    etcetera. And, and I don't think
  • 02:18:24
    time is of the essence here. So, yes, next month
  • 02:18:27
    would be. Okay. Okay. We'll look for that next
  • 02:18:31
    month if y'all could decide on
  • 02:18:34
    which, which you prefer. And we'll.
  • 02:18:37
    We'll, we'll bring it up and we'll move forward next month.
  • 02:18:41
    Get that right. Okay. Anything else?
  • 02:18:44
    Thank you. Thank you so much.
  • Item 11.2 - BREAK
    02:18:48
    Okay, we are at break. We're almost at lunch.
  • 02:18:53
    I would ask that we take a ten minute break, lunch, come back at
  • 02:18:57
    noon. And we've
  • 02:19:01
    got a couple items here that are pretty quick. The one item that I want
  • 02:19:04
    you all to be aware of is 1232.
  • 02:19:08
    This was one that has been referred to us and the board had
  • 02:19:13
    some discussion about making this urgent. So that's the one that
  • 02:19:16
    we've kind of allocated some extra time for. Hopefully the others
  • 02:19:20
    can move on pretty quick, but just be aware that
  • 02:19:24
    that one's coming up and otherwise, let's take our
  • 02:19:27
    break and we'll start back at noon. Thank you.
  • 02:19:34
    It.
  • 02:30:10
    Okay, are we ready to get back, back to the
  • 02:30:13
    agenda? It is 12:00 so we
  • 02:30:17
    will move forward. It is.
  • Item 12 - WMS Revision Requests Tabled at WMS - Possible Vote - Eric Blakey
    02:30:21
    We are on item number twelve. WMS revision request
  • 02:30:25
    table to WMS. I believe both of these can remain
  • Item 12.1 - SMOGRR028, Add Series Reactor Compensation Factors - MWG
    02:30:29
    tabled. SMOGRR028 was referred
  • 02:30:32
    to MWG. I don't believe they've had a chance to
  • 02:30:36
    meet on that yet. So we will keep that one to tabled.
  • Item 12.2 - VCMRR041, SO2 and NOX Emission Prices Used in Verifiable Cost Calculations - RCWG
    02:30:40
    And VCMRR041,
  • 02:30:46
    I think Blake reported on this, that there's still some action
  • 02:30:51
    awaiting comments on there and then NPRR. So I
  • 02:30:54
    think we can keep these two tabled for now. Is that any concern
  • 02:30:58
    or questions on that?
  • Item 13 - New Protocol Revision Subcommittee - PRS - Referrals - Vote - Eric Blakey
    02:31:01
    Okay, moving on to the new
  • 02:31:06
    referrals from PRS. And we can
  • 02:31:09
    take these in a couple of different ways. I think
  • 02:31:13
    1232 is the one that we've kind of allocated some extra
  • 02:31:16
    time just to see if we need it, but if we don't need it,
  • 02:31:19
    we won't use it. So let me,
  • 02:31:23
    let's just try going through these one at a time.
  • Item 13.1 - NPRR1229, Real-Time Constraint Management Plan Energy Payment
    02:31:25
    1229 is real time constraint management
  • 02:31:29
    plan energy payment. This was proposed by stack
  • 02:31:33
    on May 6 and
  • 02:31:37
    it was referred to WMS and Ross
  • 02:31:41
    by PRS.
  • 02:31:44
    And at the PRS, they had a pretty good discussion on
  • 02:31:47
    this. And my understanding is they were recommending
  • 02:31:52
    that we would refer this on to WMWG.
  • 02:31:57
    I wanted to see if there's any comments or questions
  • 02:32:00
    about this proposal while it's. This is the first time we've
  • 02:32:03
    seen it here at WMS. So I
  • 02:32:07
    wanted to see if. If we wanted to hear from stack
  • 02:32:12
    on this, or if we wanted to just let this
  • 02:32:16
    be referred on to WMWG and let them have a good discussion
  • 02:32:19
    on it, and then they can bring it back to us with.
  • 02:32:22
    With recommendation. So with that, is there any comments
  • 02:32:26
    or questions or
  • 02:32:30
    any concern with adding this to the combo ballot to refer to WMWG?
  • 02:32:41
    See a comment. David Delitch.
  • 02:32:45
    Oh, I just. Hold on, let me back up.
  • 02:32:48
    Blake Holt. We got a queue now, right? Yeah,
  • 02:32:52
    we have a queue. David, go ahead. You're up. Go ahead.
  • 02:32:57
    Okay. I don't have a specific comment about this,
  • 02:33:01
    except that at the moment,
  • 02:33:04
    it seems like WMWG is more to work out
  • 02:33:07
    details than technical details. But if this is a policy
  • 02:33:12
    discussion, then maybe it more on the WMS,
  • 02:33:14
    or at least give some direction to WMS
  • 02:33:18
    and WMG on that. Regards.
  • 02:33:22
    Does that sound right? Yep.
  • 02:33:29
    Okay, let's move on through the queue and let's see what.
  • 02:33:33
    Blake, I think you're next. Yeah. Blake Holt,
  • 02:33:36
    LCRA. My memory of the PRS
  • 02:33:40
    discussion was there was some interest in reviewing the settlement
  • 02:33:44
    equations in NPRR1229.
  • 02:33:47
    And LCRA also has some questions around this. I was curious
  • 02:33:51
    about the market settlements working group. Is that
  • 02:33:55
    group operational yet? And would it make sense to go there
  • 02:33:59
    to address those questions?
  • 02:34:06
    Market settlement working group is in
  • 02:34:10
    place. We have Hedy Lukadu as a
  • 02:34:14
    chair. I don't believe they've met
  • 02:34:18
    for a while, but we can certainly put
  • 02:34:23
    that before the committee and refer this to that
  • 02:34:27
    group, if that's the will of the group.
  • 02:34:33
    Lucas, I'm sorry,
  • 02:34:36
    I jump in. Hi, this is Shuye Teng from constellation,
  • 02:34:41
    and I'm the vice chair of the market settlements
  • 02:34:44
    working group. And I think this one,
  • 02:34:47
    before we look at the settlements, I think this is a.
  • 02:34:51
    We do need the direction about the policy.
  • 02:34:55
    Right. First, I think, do we want to consider this
  • 02:34:59
    kind of compensation, you know,
  • 02:35:03
    before we go into the segments? Details?
  • 02:35:06
    Yeah, well, more than. We'll be more than happy to look into the
  • 02:35:10
    segments portion. Thank you.
  • 02:35:14
    Thank you. No, good comment. Okay,
  • 02:35:17
    let's go to Lucas. Lucas, this was submitted by stack.
  • 02:35:20
    So very, very much interested in your review
  • 02:35:25
    and I. And recommendation.
  • 02:35:30
    Hello, can you hear me? Yes, sir. All right,
  • 02:35:33
    thanks, Eric. Sure. I mean, I can step
  • 02:35:36
    through it or just kind of wanted to get in the queue and make sure
  • 02:35:40
    and note that this is still highly important
  • 02:35:43
    to stack since this did,
  • 02:35:48
    the issue that we're trying to resolve
  • 02:35:52
    here will exist for us this summer,
  • 02:35:56
    same as we saw it, saw it last year. Just kind of wanted to note
  • 02:36:00
    this is, this is still highly important and we would
  • 02:36:03
    hope to have gotten it in place this summer,
  • 02:36:06
    but kind of understand that it,
  • 02:36:10
    it might be a bit, a bit much too for WMS
  • 02:36:14
    to take it on and move it now.
  • 02:36:18
    Not sure what group is the right group. Settlements or resource
  • 02:36:22
    cost, wherever Ino is going to be, I guess kind of since he
  • 02:36:25
    kind of was helping and
  • 02:36:29
    leading the charge on, you know, on conversations,
  • 02:36:34
    you know, outside of the subcommittee here or
  • 02:36:38
    prs and helping me on it. So just
  • 02:36:42
    here to answer questions on it.
  • 02:36:46
    Thank you.
  • 02:36:52
    Do we have anyone else in the queue or anyone else want to have
  • 02:36:55
    a question or comment?
  • 02:37:00
    Yeah, I think I'm next.
  • 02:37:04
    Just briefly, in the interest of time, I just want to restate our
  • 02:37:08
    opposition to creating a new payment here
  • 02:37:12
    when the energy market should have this with
  • 02:37:15
    prices I don't need to go into unless people have any questions.
  • 02:37:19
    Thanks. Thank you. I apologize.
  • 02:37:22
    My chat was hung up. So I
  • 02:37:27
    see Brittany has had Lucas and Eric. So I apologize for that.
  • 02:37:31
    Ino, it looks like you're up. Yes. Can you hear me?
  • 02:37:35
    Yes, sir. Great. Thank you.
  • 02:37:40
    Let me just say upfront that I agree with Shuye Teng.
  • 02:37:43
    This NPRR is definitely not ready, in my opinion, to go
  • 02:37:47
    to the settlements working group. There's still a lot of policy issues
  • 02:37:51
    that need to be decided, and that's
  • 02:37:55
    for WMS members as well as ROS to
  • 02:37:59
    decide on these policy issues before we
  • 02:38:03
    can address the compensation part.
  • 02:38:07
    Especially. I spent some time reviewing this NPRR with Lucas,
  • 02:38:11
    superficially recognizing there are some
  • 02:38:15
    policy decisions that need to be made. And obviously
  • 02:38:19
    this NPRR has a combination of the 1190
  • 02:38:23
    HDL override as well as the OSA, which is
  • 02:38:28
    when ERCOT cancels and outage all that
  • 02:38:31
    combined into one NPRR. And I'm not,
  • 02:38:35
    I don't want to address the policy issues. I think that's for WMS members
  • 02:38:39
    to discuss first. But we do have some concerns,
  • 02:38:43
    and we submitted an NPRR, excuse me, a set of comments
  • 02:38:46
    on May 7. Again, that was our
  • 02:38:50
    first attempt at looking at this NPRR,
  • 02:38:54
    and those issues that we addressed in May 7
  • 02:38:58
    have not been fully vetted, have not been addressed in
  • 02:39:01
    my opinion. And since then,
  • 02:39:05
    I personally communicated several issues with Lucas
  • 02:39:09
    and I still think they need to be resolved.
  • 02:39:13
    But again, I prefer to have WMS
  • 02:39:16
    members and stakeholders to decide on the policy and then
  • 02:39:20
    we can discuss the how
  • 02:39:24
    to implement this NPRR if that's the wish, the will of
  • 02:39:27
    the group. Personally, I do not want to spend way
  • 02:39:31
    too much time on this because I'm not even sure where this is
  • 02:39:34
    going to go to. So this is why we kind of stopped reviewing
  • 02:39:38
    it.
  • 02:39:41
    And so, Eric, as far as.
  • 02:39:45
    As far as which group to send this to,
  • 02:39:49
    there's a component obviously, for the cost.
  • 02:39:52
    Right? So one argument is RCWG, but it's also
  • 02:39:56
    a component for WMWG because there's a
  • 02:40:00
    policy decision that has to be made first. And so
  • 02:40:04
    this is why also is this. NPRR is going to be discussed at Ross
  • 02:40:08
    tomorrow.
  • 02:40:14
    I see this all right now.
  • 02:40:19
    Okay. I'd like Lucas
  • 02:40:23
    to have a time to respond. And then I see Eric
  • 02:40:27
    Goff is proposing that we let WMWG do the policy discussion
  • 02:40:31
    first. But Lucas, you want. You want to respond?
  • 02:40:37
    I mean, you know.
  • 02:40:41
    Right. I. You know, we need to talk to the policy first.
  • 02:40:45
    That's fine if WMWG is the right place to do that.
  • 02:40:49
    I know prs kind of gave that direction.
  • 02:40:53
    Again, I don't want it to get bogged down over there.
  • 02:40:58
    Would be fine if I don't know what WMS
  • 02:41:02
    thinks about letting it here and just letting WMWG
  • 02:41:06
    take it up on their own. But,
  • 02:41:12
    you know, I'd suggest that maybe instead,
  • 02:41:16
    if it matters.
  • 02:41:21
    Okay.
  • 02:41:29
    Okay. Eric, did you want to add anything?
  • 02:41:33
    No. I'm not sure. The distinction between
  • 02:41:37
    keeping it tabled here versus sending it to WMWG, but letting them
  • 02:41:41
    talk about it, if it stayed here,
  • 02:41:45
    I'd leave that up to leadership. Whichever way we can put on the comma ballot.
  • 02:41:50
    Yeah. Okay. You know.
  • 02:41:55
    Yes. I'm not
  • 02:41:59
    sure everyone understands. I don't know for sure the
  • 02:42:03
    policy implications of this NPRR.
  • 02:42:06
    I think it would be helpful maybe for Lucas to.
  • 02:42:11
    Or some, or maybe Erica, I don't know, to put together a
  • 02:42:14
    list of issues, policy issues that need to be addressed.
  • 02:42:17
    And until those are resolved, I don't think this NPRR can
  • 02:42:21
    move forward through the stakeholder process. And just by reading the NPRR by
  • 02:42:25
    itself, you may not get the full picture of
  • 02:42:29
    what I'm talking about as far as the policy issues
  • 02:42:32
    that have to be addressed. So I think it would probably help everyone
  • 02:42:36
    if the list of policy points are
  • 02:42:40
    brought up to the group, whether it's WMS or WMWG,
  • 02:42:45
    it might help in the discussion.
  • 02:42:49
    So, you know, in your ERCOT's comments you referenced
  • 02:42:53
    on May 7, I see seven
  • 02:42:59
    or six different bullet points. Are these policy issues
  • 02:43:03
    that. Are you. Is it something else?
  • 02:43:07
    These are a list of policy issues, but I believe there's more.
  • 02:43:11
    Again, this is our first attempt. Yes, it's our first
  • 02:43:14
    attempt to look at the NPRR. We only spent a couple of days looking
  • 02:43:18
    at it, but I think there's more issues that need to be addressed.
  • 02:43:24
    Okay. Well,
  • 02:43:31
    Eric, do you want to.
  • 02:43:34
    Yeah, go ahead.
  • 02:43:38
    I think maybe developing a list of things to be talked about is a
  • 02:43:41
    good idea. And we're happy to consider filing
  • 02:43:45
    comments that expand on that and
  • 02:43:50
    then following those comments, maybe at the
  • 02:43:53
    next meeting we can decide whether WMS wants to keep it tabled
  • 02:43:57
    here or move it somewhere else.
  • 02:44:01
    But gathering a list of discussion points would keep this from languishing.
  • 02:44:05
    And we always say policy, not do anything about it.
  • 02:44:10
    Yeah, that's the. That's the challenge I'm having, is we
  • 02:44:15
    have. We apparently have a lot of policy issues here,
  • 02:44:18
    but they're not being teed up real clearly. So we need
  • 02:44:22
    to get that sort of lined out so that we can understand
  • 02:44:26
    what the policy issues are and implications so that we can have
  • 02:44:30
    a good discussion and make that presentation move
  • 02:44:33
    forward. Can you hear
  • 02:44:37
    me? Go ahead.
  • 02:44:41
    Yeah, I'm sorry, I didn't mean to interrupt,
  • 02:44:44
    but it might help. I can work on a list of issues
  • 02:44:48
    that we see that we still need to be addressed and
  • 02:44:52
    have those ready for the next WMS meeting.
  • 02:44:58
    I'm good with that. Anyone have any questions
  • 02:45:02
    on that?
  • 02:45:07
    Lucas? That would be. That would be next month and.
  • 02:45:11
    Right? I mean, yeah.
  • 02:45:15
    When is WMWG? Are we able to do that,
  • 02:45:19
    you know, at their meeting? Is it this
  • 02:45:22
    month? It's on the 23rd
  • 02:45:26
    of the 23rd.
  • 02:45:29
    Okay. So, Lucas, I guess
  • 02:45:34
    I can try to work on a list of issues that, in our view,
  • 02:45:38
    are still pending and have those ready for
  • 02:45:41
    WMWG if it's the 23rd. I haven't
  • 02:45:45
    checked, but it looks like it is.
  • 02:45:51
    No, it sounds good. I'm queue it up at WMWG.
  • 02:45:55
    That way we keep it going.
  • 02:46:00
    Yeah, that'll be fine with us. Okay.
  • 02:46:03
    So with that, do we go ahead and table it to WMWG?
  • 02:46:08
    Is that okay?
  • 02:46:11
    And then they. And then that gives them the ability to bring
  • 02:46:15
    back that discussion next month.
  • 02:46:19
    Okay. So thank you. If we're okay,
  • 02:46:24
    we will add this to the combo to table and
  • 02:46:28
    refer to WMWG and ERCOT will prepare
  • 02:46:31
    a list of issues, policy issues that will be discussed.
  • 02:46:37
    Thank you. Okay,
  • Item 13.2 - NPRR1232, Standing Deployment of ECRS in the Operating Hour for a Portion of<br />ECRS that is Provided from SCED-Dispatchable Resources
    02:46:41
    next is 1232. This is standing
  • 02:46:44
    deployment of ECRS and the operating hour for a portion of ECRS that is
  • 02:46:48
    provided from scad to special resources.
  • 02:46:52
    This was filed by ERCOT on May 6 and
  • 02:46:57
    prs referred it to us on June 13.
  • 02:47:02
    I believe Nitika is on the line. I'm going to let her give sort
  • 02:47:06
    of an overview and recommendation,
  • 02:47:10
    but just, you know, point out that this was discussed
  • 02:47:14
    at the board, I believe at the reliability
  • 02:47:20
    committee. But there was some interest in
  • 02:47:23
    moving this forward on an urgent basis. So I want us to
  • 02:47:27
    keep that in mind as we have our discussion today on this one. So,
  • 02:47:30
    Nitika, I'll turn it over to you.
  • 02:47:33
    Oh, before I do, I see that Brian Sands has a comment. Ryan,
  • 02:47:36
    do you want to make your comment after?
  • 02:47:42
    Okay, Netika, I will turn this over to you.
  • 02:47:47
    Thank you very much for that. I just want to confirm you can still hear
  • 02:47:50
    me. Yes. Yes, ma'am. Perfect. Thank you very
  • 02:47:54
    much. So this particular NPRR Disney,
  • 02:47:58
    if you want, you can probably scroll just to the right lines,
  • 02:48:02
    is a follow on to the conversation we've been having around
  • 02:48:05
    ECRS and deployment of ECRS.
  • 02:48:08
    So if you
  • 02:48:12
    recollect, when we started discussions on the topic
  • 02:48:15
    in April, we'd mentioned that really to
  • 02:48:19
    us, one mechanism of improving the
  • 02:48:24
    efficiency around deploying ECRS would be to adopt
  • 02:48:28
    an approach of releasing this capacity to scad
  • 02:48:32
    the way we do for online Non-Spin.
  • 02:48:34
    However, there would be certain megawatts of ECRS that we would
  • 02:48:38
    want to. One difference between online Non-Spin and ECRS
  • 02:48:42
    would be that ECRS is also used to recover frequency.
  • 02:48:46
    So we were not comfortable doing the standing deployment today that
  • 02:48:49
    would release all of ERCOT capacity, but we were okay with releasing
  • 02:48:53
    a portion of the ERCOT capacity. So the entire.
  • 02:48:57
    So, and we expected a change
  • 02:49:01
    like this to impact QSE systems as far as telemetry
  • 02:49:05
    setup and maybe telemetry setup went at this
  • 02:49:08
    point. So we had originally failed 1224,
  • 02:49:13
    which was clearly making adding a new trigger for deploying PCRS.
  • 02:49:18
    And this is the follow on NPRR which releases,
  • 02:49:22
    which puts into the protocol for concept to release
  • 02:49:26
    a portion of ERCOT using this as standing deployment.
  • 02:49:31
    So with that setup right now, there is only one paragraph
  • 02:49:35
    that has all of the edits related to the standing deployment.
  • 02:49:39
    It contemplates a process wherein ERCOT would
  • 02:49:42
    publish a percentage of ERCOT that would need
  • 02:49:46
    to be released every hour,
  • 02:49:50
    and QSEs would use their sketch dispatchable resources
  • 02:49:55
    that are providing to respond and
  • 02:50:00
    release and change their ERCOT schedule
  • 02:50:04
    such that it releases the percentage
  • 02:50:08
    that is specified of ERCOT. Now, at the
  • 02:50:12
    PRS discussion, I know there were a couple concerns that were
  • 02:50:16
    raised around this language.
  • 02:50:19
    So right now, at least from an recognizing
  • 02:50:24
    all of the discussion that has been had at the board. We are also wanting
  • 02:50:28
    to try and understand really
  • 02:50:33
    from a QSE systems perspective, what does
  • 02:50:36
    a change like this mean in terms of implementation time.
  • 02:50:41
    So some conversations that I'm hoping to have, at least
  • 02:50:44
    with the WMS SMEs is going
  • 02:50:48
    to be around. What is the recognizing
  • 02:50:52
    that this is a telemetry impact, and I heard there would potentially be vendors involved.
  • 02:50:56
    Reasonably, what is the implementation?
  • 02:51:00
    The second frame of questions were around the language
  • 02:51:03
    itself and how it would apply. If the
  • 02:51:08
    volume of ERCOT that is provided
  • 02:51:12
    by NCLRs within a QSEs portfolio
  • 02:51:17
    is large, it's possible that you may not be able to hit the percentage release
  • 02:51:21
    target. So how would compliance work?
  • 02:51:25
    We've been talking about that internally, and I do have some potential
  • 02:51:28
    leverage edits that could help clean up that portion
  • 02:51:32
    of the questions that were asked. So we
  • 02:51:35
    can, if the group wants to look at those, we can
  • 02:51:39
    pull those up and I can share them. But at least those
  • 02:51:42
    are the two topics that I had taken.
  • 02:51:46
    Points being items related to
  • 02:51:49
    this NPRR that needs to be discussed. So happy
  • 02:51:53
    to take each and both of them. If it's okay,
  • 02:51:57
    we can flash up the potential, at least the idea that we
  • 02:52:01
    have around how to address the compliance, which potentially
  • 02:52:05
    could be a concern if you have lots of NCLR providing ECRS,
  • 02:52:10
    and maybe then we can go back and talk about implementation.
  • 02:52:18
    Okay, that sounds okay. Brittany, maybe you may want to, you may have the
  • 02:52:23
    red lines that may be worth pulling up.
  • 02:52:31
    Yes. So in this version of the,
  • 02:52:34
    of that same paragraph we've edit, we phrase this such
  • 02:52:38
    that the percentage of the target,
  • 02:52:41
    which is a percentage of ECRS to be released would be a percentage
  • 02:52:44
    of megawatts that are carried on sched dispatchable resources.
  • 02:52:50
    So that would make it very clear. So if in any given hour
  • 02:52:54
    we say release 60% of ECRS that you intend
  • 02:52:58
    to carry on schedule dispatchable resources,
  • 02:53:00
    then that should help QSEs ensure they can
  • 02:53:04
    set the schedules correctly. The second part of the edits really
  • 02:53:08
    talk about how to set up the telemetry. The ECRS
  • 02:53:12
    schedule telemetry under the.
  • 02:53:16
    With the proposed change of setting the percentage to be based off
  • 02:53:20
    of. I'll pause with that.
  • 02:53:26
    I'm happy to take feedback or comments.
  • 02:53:31
    Okay, you ready to go to the queue then? You want to go to Brian?
  • 02:53:36
    Yes, please. Okay. Brian, hi,
  • 02:53:39
    good afternoon. Yeah, I was hoping that
  • 02:53:43
    we could table this and refer to WMWG.
  • 02:53:47
    I saw the board meeting, I heard the comments.
  • 02:53:51
    I'll just add that I think the implementation of this is extremely complicated.
  • 02:53:56
    Was hoping to have a good discussion at WMWG
  • 02:54:00
    to figure out if there's a way that
  • 02:54:04
    this could be more automated by
  • 02:54:07
    ERCOT, because right now it feels like the
  • 02:54:10
    way this is set up as a behavioral change, shifts all the
  • 02:54:14
    compliance burden to QSEs.
  • 02:54:17
    And I think the reason for that is because it makes it easy for,
  • 02:54:21
    ERCOT to implement without any kind of system change. But there's
  • 02:54:27
    just a lot of compliance risk here. I mean, if you look through just
  • 02:54:30
    this, the top of this first paragraph, it says,
  • 02:54:34
    you know, within 30 seconds of the window, prior to the top of the
  • 02:54:37
    hour, you have to revise what's
  • 02:54:42
    offered. And that's a 24/7 requirement.
  • 02:54:47
    So wanted to just discuss if there are better
  • 02:54:51
    ways for implementing this. And this is not specific
  • 02:54:55
    to generators,
  • 02:54:59
    it's specific to anyone that's offering ECRS. So that
  • 02:55:03
    includes loads that are offering ECRS.
  • 02:55:09
    The other question I had was just about,
  • 02:55:12
    like, how ERCOT is
  • 02:55:16
    determining on a monthly basis the percentage of the ancillary service
  • 02:55:20
    responsibility that a QSE is supposed to be
  • 02:55:25
    using. Because across hours,
  • 02:55:28
    across the course of months,
  • 02:55:32
    a QSE's portfolio changes. And so
  • 02:55:38
    just trying to understand, you know, how that static percentage
  • 02:55:42
    applies to offer behavior within a month.
  • 02:55:47
    Those are my comments. Thank you.
  • 02:55:56
    Nitika, you have a response, or.
  • 02:55:59
    Yeah, I was going to maybe ask Brian if there
  • 02:56:03
    is a will to discuss, discuss this at WMWG. Is it better to answer both
  • 02:56:07
    your questions there?
  • 02:56:12
    I'm happy to have that discussion there. And like
  • 02:56:16
    I said, I heard the board discussion. I don't know that there's a full appreciation
  • 02:56:20
    of the complexity that this involves
  • 02:56:24
    when that discussion happened. And I would be happy
  • 02:56:27
    to,
  • 02:56:31
    if there was an opportunity to talk to board members, explain why this just
  • 02:56:35
    needs more, more time,
  • 02:56:39
    because of the compliance risk that exists with
  • 02:56:42
    this.
  • 02:56:47
    Thank you for that, Brian. That's Blake
  • 02:56:51
    Holt. Yeah, Blake Holt.
  • 02:56:54
    Lcrae we're okay with the referral
  • 02:56:57
    to WMWG, but just wanted to give our view on
  • 02:57:01
    this to WMS. Conceptually,
  • 02:57:05
    we can't make this NPRR make sense in a
  • 02:57:08
    world where the as plan is right sized,
  • 02:57:11
    which is a world that I believe we're living in. After ERCOT's
  • 02:57:15
    re review of the ECRS plan and what
  • 02:57:18
    I've heard and what I've gathered in the revisions justification,
  • 02:57:22
    there doesn't seem to be a reliability issue that this
  • 02:57:25
    standing deployment is resolving. It appears to just
  • 02:57:28
    simply be an effort to address price formation.
  • 02:57:31
    And so I asked that question at WMS, is there a reliability
  • 02:57:35
    need for this NPRR? And I interpreted the answer as
  • 02:57:38
    no, but willing to be corrected there. And my
  • 02:57:42
    question is, if there's not a reliability need to hold back this
  • 02:57:46
    percentage of eternity, ECRS from SCAD, whatever that percentage
  • 02:57:49
    will be, then why are we reserving it in the first
  • 02:57:53
    place? You know, I think the most efficient
  • 02:57:56
    solution to all of this may be to reduce the AS plan instead of burden
  • 02:58:01
    QSE systems to adjust practices
  • 02:58:05
    and code to achieve the same end. So if it's
  • 02:58:08
    actually ERCOT's view that the ECRS plan isn't the right size,
  • 02:58:11
    then I think that we're with the imm needs to speed up,
  • 02:58:16
    in our opinion. You know, we've been on record saying that alignment
  • 02:58:19
    between the IMM, ERCOT and stakeholders on as plan amounts would
  • 02:58:23
    be the most beneficial in the long run.
  • 02:58:27
    So I guess, in summary, we don't support moving this NPRR forward at this
  • 02:58:30
    time. I realize there's going to be some additional
  • 02:58:34
    discussion, but I've cautioned that other groups,
  • 02:58:37
    if this does get to the point where we. We're going to implement,
  • 02:58:42
    I want ERCOT to recognize, and it sounds like Nitika,
  • 02:58:45
    is that the burden will be on the QSE's end to
  • 02:58:48
    change their systems. And our vendors typically do
  • 02:58:52
    not give dollar impact estimates or time estimates until
  • 02:58:55
    rules are set in stone and scope is locked.
  • 02:58:59
    So if this does get to a point where it's approved by PRS,
  • 02:59:03
    I think it would be wise to have a pause to allow
  • 02:59:07
    for discussion time at perhaps the technology working group where
  • 02:59:10
    we can engage our vendors to understand what the system requirements
  • 02:59:14
    are. And I think this would give ERCOT and us
  • 02:59:18
    a better sense of when this sense of when this could actually be implemented,
  • 02:59:23
    instead of stating it can be improved after PUC
  • 02:59:28
    approval. So I'll stop there. Thank you.
  • 02:59:33
    Thank you, Blake. Sean?
  • 02:59:37
    Yeah. I think we discussed that this capacity
  • 02:59:40
    that's released would be subject to the offer floor
  • 02:59:44
    in the other NPRR, what was it?
  • 02:59:47
    1224. But I don't see any language that
  • 02:59:51
    ties the two together. Would you point to that, Nitika?
  • 02:59:55
    Yeah. So at this point, if you. Sorry. If you look at the preamble,
  • 03:00:00
    we were, since 1224 already had the office floor
  • 03:00:04
    language and it was tackling it at that. At the time when this
  • 03:00:07
    NPRR was filed, we chose to not include anything,
  • 03:00:11
    any language edits in this NPRR trending to
  • 03:00:14
    see how 1224 progresses. And now
  • 03:00:18
    it's, it has been approved by the board, but it is still pending discussion
  • 03:00:21
    at the PUC. So shams potentially, if it goes,
  • 03:00:25
    if it does get approved, then the baseline language
  • 03:00:30
    across the board can be updated to show what the offer flow would
  • 03:00:33
    be. But if that doesn't end through, then we would
  • 03:00:37
    want to certainly revisit 1232 and
  • 03:00:42
    talk about the offer flow. Right? So basically we'd
  • 03:00:46
    have to include some additional language here to
  • 03:00:49
    point. Right, right.
  • 03:00:52
    And in case the PUC, let's say, decides either
  • 03:00:56
    to reject or not have an offer floor in 1224,
  • 03:01:00
    how would that. Because this concept would be.
  • 03:01:03
    Right. So, so we were
  • 03:01:07
    waiting. So we. So the offer floor is in a different section
  • 03:01:10
    than this particular language that you're seeing in front of you right now,
  • 03:01:14
    shams. So. So certainly we do want to let the
  • 03:01:18
    PUC conversation on 1224 stands
  • 03:01:22
    today fully materialize before we
  • 03:01:26
    come back and decide how to handle if 1232 needs
  • 03:01:29
    to be changed. I'm just thinking,
  • 03:01:33
    you know, if the PUC,
  • 03:01:36
    you know, let's say they set the offer floor at $75 or $100,
  • 03:01:41
    something like that, this is really
  • 03:01:45
    problematic. Because then I would say, I mean,
  • 03:01:48
    as Blake was saying, you know, why do you even need, I mean, it's just
  • 03:01:51
    75 or it's the same as online Non-Spin,
  • 03:01:54
    essentially. Understood. And like I said, I don't
  • 03:01:58
    want to speculate how the PUC will react or how we will react in
  • 03:02:01
    response to it. We just want to let the. Right now, since the offer
  • 03:02:05
    flow is being discussed at under 1224, we just want to let
  • 03:02:09
    that conversation materialize and finish there.
  • 03:02:13
    But you are right, for this concept to work, we will need
  • 03:02:16
    an upper floor. And certainly the offer flow should be set correctly.
  • 03:02:20
    Okay, thanks.
  • 03:02:30
    Nice comment, Eric. Any other questions or comments?
  • 03:02:36
    I guess what I wanted to sort of lay out
  • 03:02:40
    too, is. So the board, the August board actually is
  • 03:02:44
    August 18, TAC is meeting on
  • 03:02:47
    July 31, and WMWG
  • 03:02:52
    is scheduled to meet on July 23.
  • 03:02:56
    And it does sound like maybe
  • 03:03:01
    this could be discussed at WMWG because
  • 03:03:06
    I think TAC will want to be responsive
  • 03:03:09
    to the board in some way. We all heard
  • 03:03:13
    what they said. I think,
  • 03:03:16
    Bryan, you raised some good points about implementation
  • 03:03:20
    that will probably need to be communicated through some of this as well.
  • 03:03:24
    But we obviously want to be responsive to their
  • 03:03:28
    request that this be brought back in August.
  • 03:03:31
    So one thought might be that we let WMWG
  • 03:03:37
    have an opportunity to discuss. And when
  • 03:03:42
    I make my report to the TAC on the WMS update,
  • 03:03:47
    we could let Blake or someone from WMWG
  • 03:03:51
    speak to TAC on their discussion and any
  • 03:03:56
    recommendations and have that discussion with TAC on what to tell the
  • 03:04:00
    board on the 18th.
  • 03:04:03
    That would be at least one recommendation but
  • 03:04:07
    I'm open to other thoughts on this.
  • 03:04:14
    Caitlin? Thanks, Eric.
  • 03:04:17
    I don't know if I have a solution,
  • 03:04:21
    but. But I agree with a good part of Blake's
  • 03:04:26
    comments. I think whether
  • 03:04:30
    this goes to WMWG or not,
  • 03:04:33
    there needs to be some kind of high level policy discussions,
  • 03:04:37
    I think, at WMS or even TAC.
  • 03:04:41
    You know, I think the intent of this NPRR was
  • 03:04:45
    probably based on an IMM proposal. I don't know if we need to hear from
  • 03:04:49
    them, but sometimes when you're kind of frankensteining
  • 03:04:53
    these through the different groups, and there could
  • 03:04:56
    be a change to NPRR1224
  • 03:05:00
    at the commission, and I
  • 03:05:04
    think the board preference for priority on this was in conjunction
  • 03:05:08
    with the floor in 1224. I think there's a
  • 03:05:12
    lot of room for error if you really kind of just dive
  • 03:05:15
    into the details without thinking about the whole picture.
  • 03:05:19
    And so I don't know the best way to remedy that. But I think
  • 03:05:24
    we need to make sure that ERCOT and the IMM and
  • 03:05:29
    the board and commissioner are listening and giving feedback when they can,
  • 03:05:33
    but making sure that we are really trying to.
  • 03:05:37
    To fix the problems. Like, what problem
  • 03:05:41
    are we trying to solve and how does this fix it?
  • 03:05:46
    Right.
  • 03:05:57
    Is anyone from the IMM on the line that would
  • 03:06:00
    like to provide perspective?
  • 03:06:29
    So, any other questions or comments
  • 03:06:34
    or recommendations?
  • 03:06:49
    So I see Jim Galvin is making a proposal that we
  • 03:06:54
    table and refer this to WMWG,
  • 03:06:59
    and Blake Holt seconds that. So I
  • 03:07:04
    guess my question, though, to ERCOT and Caitlin is, is that going to.
  • 03:07:07
    Are we going to be okay with the board? I just don't want to.
  • 03:07:12
    I want to be responsive to the board to the extent I'm able.
  • 03:07:15
    I mean, it's. It's really a TAC issue, probably TAC
  • 03:07:19
    and ERCOT. Um, but if
  • 03:07:23
    we table this, will they. Will they
  • 03:07:26
    feel like we're not being responsive if to
  • 03:07:30
    their request that this be given urgent status and
  • 03:07:35
    it come back to them in August.
  • 03:07:38
    But by tabling it, that does give WMWG an opportunity to
  • 03:07:42
    talk about it, and then we can talk about it further at TAC. Eric.
  • 03:07:48
    So I don't think I'm speaking for necessarily all the consumers
  • 03:07:52
    that raised opposition to the other NPRR given
  • 03:07:57
    where the offer floor came out.
  • 03:08:01
    But I just want to say that it makes sense to try to get this
  • 03:08:04
    right. I think there's some operational concerns that
  • 03:08:08
    compile, raise that are worth talking about and
  • 03:08:14
    how this interacts with, you know, the various
  • 03:08:17
    decision points here. I think I'm okay with taking a little bit
  • 03:08:21
    of time to try to get it right and, you know, we can explain that
  • 03:08:25
    to the board if need be.
  • 03:08:29
    That feels like the right approach. Caitlin, are you.
  • 03:08:32
    I know you're subject to change
  • 03:08:36
    at the TAC meeting, but does that. Does this sound like a reasonable approach?
  • 03:08:42
    Yeah, this is Caitlin. I think
  • 03:08:45
    so. I need to get with ERCOT.
  • 03:08:48
    I know the board said that I don't think we have, you know,
  • 03:08:52
    that hasn't been to the board, so we don't have a formal direction.
  • 03:08:56
    I think that we could prevent, you know,
  • 03:09:00
    what, what the consumers as well as the generators are
  • 03:09:03
    saying. Right. If we're saying we're active talking about this attack, but we really want
  • 03:09:07
    to get it right. In light of the contentious
  • 03:09:11
    discussions on 1224, I think that's fine.
  • 03:09:15
    I would say, you know,
  • 03:09:19
    WMWG can take it up whether we refer
  • 03:09:22
    it. And so I'm not a member of WMS,
  • 03:09:26
    but I might have a slight preference for just keeping it at
  • 03:09:29
    WMS to make sure, you know, we're having discussions that
  • 03:09:34
    are visible by everybody and WMWG can
  • 03:09:38
    take it up, but I don't feel super strongly
  • 03:09:42
    about that. You know, I think the implementation concerns
  • 03:09:45
    are real and should be worked out by someone. And I don't know
  • 03:09:48
    if that's technology working group, that's probably not WMWG,
  • 03:09:53
    but I do wanna make sure that some high level
  • 03:09:57
    group is really looking at not only the details,
  • 03:10:01
    but hey, as people debate the details, is this
  • 03:10:04
    still accomplishing? You know,
  • 03:10:08
    is it fixing a problem that needs to be fixed? As I said earlier,
  • 03:10:12
    because I think we have a tendency to kind of get into
  • 03:10:15
    the details and then, you know, the IMF says, oh, well,
  • 03:10:18
    this was our recommendation at first, but now the way
  • 03:10:22
    it is, we can't recommend it. And I think things like that
  • 03:10:26
    are harder to explain to the board and the commission.
  • 03:10:32
    Agreed. Okay, well then with that,
  • 03:10:36
    would the group be okay with combo ballot
  • 03:10:39
    item that just requests that prs continue to table
  • 03:10:43
    this and we'll let WMWG
  • 03:10:47
    take it on as they see Fitzhe.
  • 03:10:51
    I see. Bryan Sam's with a yes. Any, any other concerns?
  • 03:10:57
    Okay, anything else we need to talk about
  • 03:11:01
    on this that we can talk about today from,
  • 03:11:04
    from some of the presentation that Netica provided or
  • 03:11:08
    is? Do we want to just bring
  • 03:11:13
    it back next month?
  • 03:11:23
    Nitika, is there anything you're needing from us?
  • 03:11:43
    Not sure if we can hear, are you?
  • 03:11:46
    Oh, I apologize. I was double muted.
  • 03:11:49
    But I think you've given me enough on how to prepare for the conversation at
  • 03:11:53
    WMWG. So we will do that I may reach out to some folks on the
  • 03:11:57
    side here and have some conversations as well. But hopefully you
  • 03:12:01
    will have enough information to
  • 03:12:05
    act on this in August.
  • 03:12:09
    Very good. Okay. If there's nothing
  • 03:12:12
    else, we will move on to the next item. Thank you for
  • Item 13.3 - NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service
    03:12:15
    that conversation. NPRR1235
  • 03:12:20
    is the special Reliability Reserve Service as a standalone
  • 03:12:24
    ancillary service.
  • 03:12:27
    This was filed by ERCOT on May 29,
  • 03:12:30
    referred to us from PRS on June 13
  • 03:12:35
    and develops standalone DRRS product.
  • 03:12:39
    Have Dave or Jeff, either of you all want to sort
  • 03:12:43
    of lay it out and sort of what you were hoping to get
  • 03:12:46
    from WMS today?
  • 03:12:58
    Hey, Eric, I'm sorry. I apologize. I had thought that the.
  • 03:13:02
    Jeff, Ted wanted to lead it. So anyways, I didn't
  • 03:13:06
    have anything necessarily specific for WMS.
  • 03:13:10
    Obviously, we've had several opportunities to talk
  • 03:13:14
    about this NPRR and sort of the evolution of it through both the workshops
  • 03:13:18
    as well as talking about it at PRS.
  • 03:13:22
    I know there were some comments filed about it,
  • 03:13:25
    but obviously the intent here is to,
  • 03:13:29
    you know, not necessarily try to move this through urgently to kind
  • 03:13:33
    of walk through the language to understand what's being proposed and to
  • 03:13:37
    make sure that we get the individual details right.
  • 03:13:41
    So, you know, I see already in the, in the, in the
  • 03:13:45
    chat there, Eric talking about referring to WWG to kind of further get into those
  • 03:13:48
    details, but happy to talk through anything that the group would like to talk
  • 03:13:52
    through here. And, and of course, there were some, some comments filed
  • 03:13:55
    by the Sierra club, so if they wanted to
  • 03:13:59
    speak to those as well here to kind of walk through that.
  • 03:14:04
    Okay. Is there anyone here
  • 03:14:07
    from the Sierra club that would like to say something about
  • 03:14:10
    their comments?
  • 03:14:19
    Okay, I see,
  • 03:14:22
    I see recommendations in the, in the chat
  • 03:14:26
    for tabling to WMWG and SAWG.
  • 03:14:33
    Is there any concern
  • 03:14:37
    or comment on, on that proposal that we
  • 03:14:41
    add this to the combo ballot?
  • 03:14:44
    Eric, I guess just a quick question and maybe just
  • 03:14:49
    as we think about the referral to two different groups,
  • 03:14:54
    I guess, is there, there are different questions
  • 03:14:57
    that we'd like to TAC with the two different groups, I guess, in particular,
  • 03:15:01
    and maybe this was just sort of, hadn't come to my mind.
  • 03:15:04
    But, kev, you wanted to speak to sort of SAWG
  • 03:15:08
    and what they might TAC versus WMWG.
  • 03:15:15
    Yeah, I'm happy to do that. This is Katie Rich with luminance.
  • 03:15:18
    So as far as SAWG goes,
  • 03:15:21
    you know, what we're seeing is that DRRS
  • 03:15:25
    has always been pitched as this alternative to PCM
  • 03:15:28
    for achieving resource adequacy. And that was
  • 03:15:32
    talked about in the Bates and white paper,
  • 03:15:35
    and there were a lot of comments during the, you know,
  • 03:15:38
    PCN project and pointing to, you know,
  • 03:15:41
    DRRS and as you know, first before the
  • 03:15:45
    PCN. So if we could, you know, look at that over on
  • 03:15:48
    the SAWG side, if, you know, there's something specific that
  • 03:15:52
    we need SAWG to look at, then, you know, the quantity right now is
  • 03:15:56
    undefined. So that might be something to
  • 03:15:59
    further explore.
  • 03:16:03
    Thank you, Kate. That's helpful. So maybe if I can just rearrate. Maybe. The distinction
  • 03:16:07
    is. Obviously, there's a lot of detail
  • 03:16:12
    in terms of operationally how DRRS
  • 03:16:16
    would work, but largely that would be TAC by WMWG.
  • 03:16:20
    But to a degree, there's wanting to understand the long term
  • 03:16:25
    resource adequacy impacts, for example, of DRS. Maybe that's something
  • 03:16:29
    that SAWG would talk about. Is that a fair
  • 03:16:32
    to recap?
  • 03:16:36
    Yeah, Dave, I can agree with that.
  • 03:16:40
    Thank you for indulging me on that. Oh,
  • 03:16:43
    that's helpful too. I'm glad you asked. I think it's good to
  • 03:16:47
    know, to know what we're asking the group to look
  • 03:16:51
    into. So thank you for that.
  • 03:16:54
    So we have a recommendation that this be added
  • 03:16:57
    to the combo ballot to table and refer to SAWG and WMWG.
  • 03:17:01
    Any other questions or comments?
  • 03:17:11
    Okay, we will add that to the combo ballot.
  • 03:17:16
    Okay, item 14. Hey, Eric, I jumped
  • 03:17:20
    in the queue again. I'm doing this late.
  • 03:17:24
    It's Caitlin Smith again, Jupiter Power. I'm not
  • 03:17:27
    Sierra club, obviously. I think their comments were regarding
  • 03:17:31
    inclusion of batteries and drrs, and I
  • 03:17:35
    would just agree with that. I'm sure that'll be discussed at
  • 03:17:39
    WMWG, but if that could be discussed
  • 03:17:43
    there, and maybe it's, you know, I don't know where implementation
  • 03:17:47
    problems or issues for all of these will be discussed,
  • 03:17:50
    but I think it might be an implementation issue
  • 03:17:53
    and something that could happen down the line, if not immediately. So I
  • 03:17:57
    would request that those comments, and especially the inclusion
  • 03:18:01
    of batteries, when appropriate, be discussed.
  • 03:18:06
    No, that's good. Good direction. Thank you.
  • 03:18:10
    And Eric, I'm sorry, if I could just quickly
  • 03:18:13
    respond to that. I will say that I think it's part of the workshop we
  • 03:18:16
    had talked about, and I would say perhaps
  • 03:18:21
    they're sort of more. Some of the operational questions in
  • 03:18:25
    nature, but obviously the impact, just the overall implementation,
  • 03:18:30
    things like that, that's been part of the conversation around the
  • 03:18:33
    inclusion of esrs and service. So happy to get into more detail that
  • 03:18:37
    probably, particularly at WMWG, wouldn't make sense in my mind.
  • 03:18:40
    But just wanted to note that. Thank you all.
  • 03:18:44
    Okay, thanks Dave, that's exactly what I'm looking for. Just, you know,
  • 03:18:48
    I don't want to intentionally exclude them understanding
  • 03:18:52
    the operational issues. So just speaking in that context,
  • 03:18:55
    exactly as you laid out.
  • 03:19:02
    Thank you, Caitlin. Roy.
  • 03:19:06
    Yeah, thank you. I just wanted to point. Point out that preliminary
  • 03:19:11
    impact analysis shows a cost of three to
  • 03:19:14
    $5 million in 16 to 24 months for this
  • 03:19:17
    item. So just wanted to point out that's fairly significant.
  • 03:19:21
    Thanks. Yes, it is.
  • 03:19:25
    Thank you. Any other questions or comments?
  • 03:19:37
    Okay, thank you very much. Next, item 14,
  • Item 14 - Revision Requests Tabled at PRS and Referred to WMS - Possible Vote - Eric Blakey
    03:19:42
    Revision request table to PRS and refer to WMS.
  • Item 14.1 - NPRR1070, Planning Criteria for GTC Exit Solutions
    03:19:46
    I think several of these have been on the list for
  • 03:19:50
    several meetings. NPRR1070,
  • Item 14.2 - NPRR1200, Utilization of Calculated Values for Non-WSL for ESRs - MWG
    03:19:54
    NPRR1200.
  • Item 14.3 - NPRR1202, Refundable Deposits for Large Load Interconnection Studies - WMWG
    03:19:55
    Oh, NPRR1202.
  • Item 14.4 - NPRR1214, Reliability Deployment Price Adder Fix to Provide Locational<br />Price Signals, Reduce Uplift and Risk CMWG
    03:19:59
    NPRR1214. Is that CMWG? I understand they requested
  • Item 14.5 - NPRR1219, Methodology Revisions and New Definitions for the Report on<br />Capacity, Demand and Reserves in the ERCOT Region CDR - SAWG
    03:20:03
    additional information. NPRR1219 is
  • 03:20:10
    the methodology revisions to the CDR report.
  • 03:20:18
    Kevin? I don't believe.
  • 03:20:24
    Well, let's see. ERCOT filed comments on
  • 03:20:28
    just this week, July the 9th,
  • 03:20:31
    to make some changes consistent with,
  • 03:20:35
    I think, some discussions at SOG.
  • 03:20:40
    And so it's been suggested that WMS could
  • 03:20:45
    approve this today with the ERCOT
  • 03:20:49
    comments. But I wanted to see if there's any thoughts
  • 03:20:53
    from the group, especially from SAAG, whether they want to take this back
  • 03:20:57
    and have further discussions on the comments.
  • 03:21:01
    With that, I'll go to Eric Goff.
  • 03:21:05
    Yeah, I know the comments that ERCOT
  • 03:21:08
    made, which is a small change, but I think I'd like
  • 03:21:12
    to keep this tabled if we can.
  • 03:21:19
    I don't know. We're in a rush to do this, and so if we
  • 03:21:22
    can keep it tabled, I'd appreciate it, although I. Strong opinion about
  • 03:21:26
    that. Okay.
  • 03:21:30
    Kevin Hanson? Yeah, Eric, we can either.
  • 03:21:34
    I mean, we can tail. We can leave a table if that's the world,
  • 03:21:37
    the group or. Okay,
  • 03:21:41
    can y'all. Can y'all just maybe check it off at your next
  • 03:21:45
    meeting? Just make sure the comments were
  • 03:21:49
    consistent and no other concerns, and I think that
  • 03:21:52
    would be good information for this group to
  • 03:21:56
    move. Absolutely. Okay.
  • 03:22:01
    All right, we will remain. That one will remain table at SOG.
  • Item 14.6 - NPRR1226, Demand Response Monitor - DSWG
    03:22:05
    And then we have NPRR1226, which is the demand
  • 03:22:09
    response monitor, I don't believe.
  • 03:22:15
    I know it was in the DSWG report.
  • 03:22:20
    And I think the summary of their discussion was that
  • 03:22:24
    they thought this was a good idea,
  • 03:22:27
    but I wasn't
  • 03:22:30
    clear whether they were, whether they had completed their review
  • 03:22:34
    or if this is
  • 03:22:38
    ready for consideration. So do
  • 03:22:41
    we have any.
  • 03:22:46
    I see a couple in the queue. Floyd, go ahead.
  • 03:22:49
    Yeah. Thank you. At the large
  • 03:22:53
    flexible load task force is
  • 03:22:56
    where I first presented this idea.
  • 03:23:00
    And from that large flexible task
  • 03:23:04
    force meeting, they requested that
  • 03:23:09
    a aggregate display of the
  • 03:23:13
    result of looking at all of the demand
  • 03:23:17
    response compared to LNP be
  • 03:23:22
    posted on an ERCOT
  • 03:23:25
    website. And so I developed this
  • 03:23:28
    NPRR based on that request.
  • 03:23:33
    And the request is not to identify
  • 03:23:38
    why loads are responding,
  • 03:23:41
    but just the fact that they are responding.
  • 03:23:46
    And we want to make it very clear
  • 03:23:50
    that we would never expose an individual
  • 03:23:53
    load, what it's doing. So everything
  • 03:23:59
    would be in aggregate format for all
  • 03:24:02
    of ERCOT. We did. I did suggest
  • 03:24:06
    that ERCOT may internally want
  • 03:24:09
    to do things more granular by zone,
  • 03:24:14
    but that's entirely up to them and not really included
  • 03:24:17
    in the NPRR discussion.
  • 03:24:20
    But if anyone, you know,
  • 03:24:24
    it was very well received
  • 03:24:28
    at large flexible load task force, and it
  • 03:24:31
    was well received at demand side working group
  • 03:24:34
    and WMS should consider what the
  • 03:24:38
    next steps with it is. I think it
  • 03:24:42
    would be a great addition to our
  • 03:24:48
    stable of tools of understanding
  • 03:24:52
    how large flexible loads,
  • 03:24:55
    all loads even,
  • 03:24:59
    are responding to voluntary load load response
  • 03:25:03
    to LMP, how all of that is affecting
  • 03:25:08
    the total demand needs at ERCOT.
  • 03:25:13
    And so if anybody has any questions, I'll be glad to answer.
  • 03:25:16
    But I see there are others in the queue.
  • 03:25:21
    Yes. Okay, Eric, you're up.
  • 03:25:26
    I guess I'd like to hear from Matt, who's in the queue
  • 03:25:29
    for, I'm sure, good reason.
  • 03:25:32
    But I think this has been talked about
  • 03:25:35
    enough. I'm happy to have it move forward. And pending
  • 03:25:40
    what Matt has to say, I think we might make a recommendation on this
  • 03:25:43
    one. Okay,
  • 03:25:48
    now, I'll go ahead and take Matt out of order. Matt, you want to go
  • 03:25:51
    ahead? Yeah. Thanks. So, we've been talking
  • 03:25:55
    this around at ERCOT. This involves kind of the management
  • 03:25:59
    side, the legal side, the website side, and we're still
  • 03:26:02
    in a place right now where it's hard to support this
  • 03:26:06
    as it is. And let me just kind of give a paradigm that we
  • 03:26:09
    can put into comments here in the next
  • 03:26:13
    few days that ERCOT currently manages the design and
  • 03:26:16
    the content of the public dashboards, and that's designed for multiple
  • 03:26:19
    audiences, it's market participants as well as public as well as policymakers.
  • 03:26:24
    So those public dashboards are kind of in the fence line of ERCOT
  • 03:26:27
    management tools and communications. So,
  • 03:26:30
    regarding 1226, we agree that there's value,
  • 03:26:34
    and we can support the idea of a new report via
  • 03:26:37
    an NPRR, that we can't necessarily commit to a new,
  • 03:26:40
    specific public dashboard via an NPRR. And this kind of goes
  • 03:26:44
    back to a discussion with Eric Goff a year ago,
  • 03:26:47
    which is, why can't we do this dashboard? And there's this
  • 03:26:51
    kind of fence line of things that we work within and don't.
  • 03:26:55
    So ERCOT's interested in providing the transparency needed. We just don't
  • 03:26:59
    know if it will be as a dashboard, but we are considering the concept.
  • 03:27:02
    So here's the second point. We do have some tools in the control
  • 03:27:06
    room that may lend themselves to a new large box
  • 03:27:10
    below dashboard, but we just don't have a current plan delivery yet.
  • 03:27:15
    So we're interested in this concept. So we're
  • 03:27:18
    neutral on the NPRR. If it were to be configured to
  • 03:27:22
    be a report and a feedback loop to the market to find the data that
  • 03:27:25
    we're not necessarily able to support at this time. A new public dashboard design
  • 03:27:30
    at this point.
  • 03:27:34
    Again, we can put comments in place so that becomes more of
  • 03:27:37
    an open discussion so that there can be points and counterpoints.
  • 03:27:41
    But I know that's probably not what people want to hear, but that's
  • 03:27:44
    kind of the operations paradigm that we're in at this point on the dashboards.
  • 03:27:48
    Thanks for letting me share. Yeah, thank you, Matt.
  • 03:27:52
    Let's go to Sean's. Yeah, I had a
  • 03:27:55
    question on the NPRR. It says the demand response
  • 03:27:59
    shall be calculated by comparing the positive difference in
  • 03:28:02
    peak consumption of a load in the past 2
  • 03:28:06
    hours to the current sel of selected substations.
  • 03:28:12
    That might be a little problematic. Even though the price might be going down,
  • 03:28:16
    the load could still be going down because of either temperature,
  • 03:28:20
    the weather or I, or what
  • 03:28:24
    they're producing. I mean, the demand might go down.
  • 03:28:27
    So I'm wondering how you
  • 03:28:31
    chose this method and is there a better way to do this calculation?
  • 03:28:42
    Thanks, Tom. So, you know, this is not
  • 03:28:46
    going to pick up every single load responding,
  • 03:28:50
    but it's intended, if you're looking at it in
  • 03:28:53
    aggregate across the entire grid,
  • 03:28:57
    that most industrials
  • 03:29:01
    that would be included in the
  • 03:29:05
    demand response monitor that are in sched to
  • 03:29:09
    begin with typically don't
  • 03:29:12
    change their peak loads unless they're
  • 03:29:17
    responding to some action. Now,
  • 03:29:20
    you're right, it's possible that you could have people shutting down,
  • 03:29:24
    for example, for maintenance on Wednesday or something.
  • 03:29:28
    But the point being is that if you look at the numbers over
  • 03:29:32
    time and from totally
  • 03:29:36
    at an aggregate position, I think it will find
  • 03:29:41
    intelligence in the totals of what's
  • 03:29:45
    going on. And because we're not necessary,
  • 03:29:48
    we're not at all looking at an individual load, what it's doing.
  • 03:29:55
    But these are, you're selecting in a below,
  • 03:29:59
    you're selecting the loads that you will be monitoring for
  • 03:30:02
    this process, right? Absolutely. Yeah.
  • 03:30:05
    We in demand side working
  • 03:30:09
    group, they did a lot of study where they selected meters
  • 03:30:13
    and easy ids to monitor. I think
  • 03:30:17
    they looked at 30,000 or something.
  • 03:30:21
    I'm suggesting that they use a process similar
  • 03:30:25
    to that, but only look at the state estimator
  • 03:30:30
    in real time loads, ERCOT and
  • 03:30:33
    those, and you won't pick up
  • 03:30:37
    100% or maybe even 75%
  • 03:30:41
    of the response that might be occurring.
  • 03:30:45
    But that's still giving you intelligence about
  • 03:30:50
    what might be happening on the grid at
  • 03:30:54
    certain prices. And that is what I
  • 03:30:57
    think is important to not only ERCOT operators,
  • 03:31:01
    but the market itself.
  • 03:31:04
    Right. My concern is more that it could be giving us the wrong information,
  • 03:31:08
    that prices are going down and loads are going down,
  • 03:31:13
    and we claim that to be a demand response. So I'm
  • 03:31:16
    wondering whether we can have more intelligence in this, look at in
  • 03:31:22
    the past, sort of use, maybe even machine learning,
  • 03:31:25
    to determine, at these prices, at these temperatures,
  • 03:31:29
    in these hours of the day, what was the load expected to
  • 03:31:33
    do? And then what did it actually do? So that it's more.
  • 03:31:38
    You'll get a better estimate, because right now, it seems like
  • 03:31:42
    you could get a lot of false negatives by just
  • 03:31:45
    looking at the two hour peak. And then, even though. And you're not
  • 03:31:48
    even checking for prices, at least. At least we should look at
  • 03:31:52
    the price actually drop since we last saw the peak
  • 03:31:56
    consumption,
  • 03:32:00
    Sean. But if you graph the two numbers together,
  • 03:32:05
    that should be obvious what's happening.
  • 03:32:09
    That's what's important to do, is they should be on the same graph.
  • 03:32:17
    And I don't disagree with you, but the intent
  • 03:32:21
    here is we have nothing. Now, that helps
  • 03:32:25
    anybody understand how big
  • 03:32:28
    demand response is. And we're seeing and
  • 03:32:32
    being told that there's tens
  • 03:32:36
    of thousands of potential megawatts that will be
  • 03:32:39
    responding into demand response.
  • 03:32:43
    We need to start to get a handle on how much
  • 03:32:47
    that is and what they are doing. But we
  • 03:32:51
    can't necessarily look at an individual load,
  • 03:32:54
    what it does, because I submit to you,
  • 03:32:57
    an individual load potentially changes
  • 03:33:02
    its outlook almost daily and weekly,
  • 03:33:06
    but in aggregate, across the entire grid,
  • 03:33:10
    of having 10,000,
  • 03:33:14
    this stuff under this type
  • 03:33:17
    of surveillance, I'm pretty sure you're
  • 03:33:20
    going to find it to be very useful. Right?
  • 03:33:23
    No, I'm just trying to. I mean, I think the tool is useful. I'm just
  • 03:33:26
    trying to find a more precise way of determining
  • 03:33:30
    the load response. And I don't disagree with you,
  • 03:33:34
    there might be an IA derivative of
  • 03:33:37
    this in the future, but this is a very
  • 03:33:41
    simple process to try to get something implemented
  • 03:33:45
    to face the over 5000
  • 03:33:49
    flexible load we already have on the grid.
  • 03:33:52
    Right. I guess I'd like ERCOT to look into that, because ERCOT is already using,
  • 03:33:56
    like, neural networks to do load forecasting and stuff.
  • 03:33:59
    If something like that can be adopted, I mean, used to so
  • 03:34:04
    leverage that to do this kind of analysis,
  • 03:34:07
    if that's something doable, that would be. That would really make
  • 03:34:11
    this much more valuable. I'm sure it is. Could be improved.
  • 03:34:15
    And this is just a start.
  • 03:34:21
    There were more questions. Yeah, we.
  • 03:34:25
    Eric had a question, but he's stepped back.
  • 03:34:28
    Sam Morris from ERCOT. Yes, Sam.
  • 03:34:32
    Marissa, load forecasting. So, Floyd,
  • 03:34:36
    just want to kind of, you know, to some of the questions that I've heard,
  • 03:34:40
    I wanted to kind of see and
  • 03:34:43
    see if we could set some expectations of which, of where, of what
  • 03:34:47
    your thinking is. So I
  • 03:34:51
    think a great example would be the steel mills that you represent, right.
  • 03:34:55
    When we look at their fluctuation in loads,
  • 03:35:00
    we would, you know, if we did this at the peak of
  • 03:35:04
    what they do, even though they are a high load factor,
  • 03:35:07
    we would still end up with some fluctuation from that
  • 03:35:10
    peak at any given moment. And so at
  • 03:35:13
    an aggregate, we would see these fluctuations
  • 03:35:17
    throughout the day. And the demand response monitor, as. As proposed,
  • 03:35:22
    would show that and say, hey, there's some demand response.
  • 03:35:25
    5002, hundred, 300, any given moment.
  • 03:35:31
    And so the question becomes, are you okay with that?
  • 03:35:35
    Is that part of your thinking? That is absolutely
  • 03:35:39
    part of my thinking, because. And the reason I
  • 03:35:42
    say that if you are looking at an individual load,
  • 03:35:46
    that's exactly what you will see, even not
  • 03:35:49
    just a steel mill, but you'll see that at Valero refineries,
  • 03:35:54
    Exxons, all over industrial loads.
  • 03:35:59
    But in aggregate, when you look at them,
  • 03:36:03
    I think all of that will smooth out
  • 03:36:07
    to tell you some valuable information that
  • 03:36:11
    you currently don't track and don't have. Have. And the only
  • 03:36:15
    reason I think this is timely
  • 03:36:19
    now is because of the large, flexible loads
  • 03:36:23
    that are going to be adding huge amounts of energy
  • 03:36:27
    demand to the grid. And we need to better
  • 03:36:31
    understand what those loads in aggregate,
  • 03:36:35
    plus all the other industrial loads that we've had for
  • 03:36:39
    years doing, are the
  • 03:36:43
    things that we know that they operate. They operate for
  • 03:36:47
    4CP, they operate for voluntary high
  • 03:36:50
    LNP's, they operate even for conservation
  • 03:36:53
    notices. And so you're right,
  • 03:36:57
    if you look at an individual load, you're going to see some noise,
  • 03:37:02
    but I think you may have to put a filter on
  • 03:37:06
    the telemetry that you're using in
  • 03:37:10
    the state. You know, you pick up the state estimated load
  • 03:37:13
    at a substation, it's only calculated
  • 03:37:18
    every five minutes. So you're taking a sample of an
  • 03:37:21
    instantaneous value in the substation.
  • 03:37:26
    And so that instantaneous value
  • 03:37:29
    is then compared to all the transmissions lines and state
  • 03:37:33
    estimated and what's going on. So I think
  • 03:37:36
    that in itself will tend to start to smooth it.
  • 03:37:40
    But if you start your ride, if you look at it every 2 seconds,
  • 03:37:44
    you're going to have a problem. But if you look at it on out
  • 03:37:48
    of the state estimator, over time,
  • 03:37:51
    I think you'll find valuable information in it.
  • 03:37:55
    Right. But SCAD is every five minutes and we already kind
  • 03:37:58
    of see that noise. My point is, is that when you start
  • 03:38:02
    adding noise on top of noise, maybe the peak
  • 03:38:05
    is not the best place to start. Maybe it's, you know,
  • 03:38:09
    an average load, an average of their load type
  • 03:38:13
    thing. And that might be the
  • 03:38:16
    way you look at it. You started with, you know,
  • 03:38:20
    I don't know. You know what?
  • 03:38:24
    You know, when we, when I designed energy management systems,
  • 03:38:29
    we would have a system that would look
  • 03:38:33
    at when has the system peak occurred.
  • 03:38:37
    And it's very similar to what I'm proposing here,
  • 03:38:43
    is you look, you just track, you know, what's the highest
  • 03:38:47
    this number gets to, and then you track
  • 03:38:50
    when it starts to go down, then you know that
  • 03:38:54
    when it was the highest was the peak. That's been
  • 03:38:58
    a process that's been in use in EMS systems for 50
  • 03:39:02
    years. Applying that to individuals,
  • 03:39:07
    state estimated loads, I think will give you
  • 03:39:11
    intelligence and it's very simple to
  • 03:39:15
    implement. What Shams is talking about is
  • 03:39:18
    a much more complex and possibly a future
  • 03:39:22
    refinement. But I think it's very important that
  • 03:39:26
    we start to address the need for
  • 03:39:29
    a demand response monitor for everybody
  • 03:39:34
    on the market, as well as ERCOT operations,
  • 03:39:38
    and solely because of so much additional
  • 03:39:42
    load that's coming onto the grid that has said
  • 03:39:46
    that they intend to be responsive
  • 03:39:50
    to demand or have demand response activities.
  • 03:39:54
    So I don't know if I'm making any sense. I don't disagree.
  • 03:39:59
    But what I'm talking about is I don't think it's
  • 03:40:02
    very difficult to implement. And if
  • 03:40:06
    you want to put some smoothing on it, that's fine too.
  • 03:40:10
    That's part of the analysis that needs to happen.
  • 03:40:13
    But I would not, I would caution, you're not
  • 03:40:17
    picking up every state estimated load.
  • 03:40:21
    We're going to only select loads
  • 03:40:24
    that we know out of the system,
  • 03:40:28
    typically have demand response activity
  • 03:40:31
    occurring on them. And I
  • 03:40:35
    talked to Karl Rosch about that. I don't know if he's on the line or
  • 03:40:39
    wants to add any to that, but that's the intent.
  • 03:40:47
    Okay, next up, we have shams. Let's go to Shams.
  • 03:40:51
    You have a question? Yeah. So, I think,
  • 03:40:55
    based on this discussion and my discussion previously,
  • 03:40:58
    I think if we left the language more,
  • 03:41:02
    like, for that one sentence, say that maybe
  • 03:41:06
    ERCOT shall determine the demand
  • 03:41:10
    response, you know,
  • 03:41:14
    and just demand response for selected load in a.
  • 03:41:18
    And leave it. Leave it open so that, you know, they can
  • 03:41:22
    implement the best method that they can conceive
  • 03:41:26
    of, or. And we can work on that method with ERCOT outside the protocols,
  • 03:41:30
    because once you put in protocols, it becomes, I mean,
  • 03:41:33
    if ERCOT doesn't do it this way, then they're not in compliance with the protocols.
  • 03:41:38
    And I just think there might be better ways. You know, ERCOT might have better
  • 03:41:40
    ideas. We might all come up with better ideas of doing it. So keeping
  • 03:41:44
    this language a little. Giving flexibility in this language,
  • 03:41:47
    I think, makes more sense.
  • 03:41:54
    Okay.
  • 03:42:00
    Sounds like ERCOT is going to file some comments, and I
  • 03:42:07
    think that will help sort of
  • 03:42:12
    guide the. Guide the process a little bit on where this can
  • 03:42:15
    go. Is there any concern
  • 03:42:19
    with just leaving this tabled
  • 03:42:23
    here and we can bring it back next month or
  • 03:42:27
    whenever we have something discussed?
  • 03:42:34
    I mean, that's fine with me. I don't vote at WMS,
  • 03:42:37
    but, you know, it's. The intent
  • 03:42:41
    is we shouldn't sit around forever, because the
  • 03:42:44
    problem is getting bigger every day.
  • 03:42:48
    And so I think it's high
  • 03:42:51
    time we address some sort of demand
  • 03:42:55
    response monitor that we can see
  • 03:42:59
    and help people understand how
  • 03:43:04
    the market is moving from a
  • 03:43:07
    demand side as well as the generation side.
  • 03:43:16
    But I'm fine with that. Okay.
  • 03:43:22
    I appreciate your work on this. I think it's a very important issue,
  • 03:43:26
    but it's also being
  • 03:43:31
    sensitive to Matt's comments, and so we want to
  • 03:43:34
    try to work together. And I think if
  • 03:43:37
    we could help ERCOT develop that information,
  • 03:43:41
    they could represent. It's probably where this is all headed,
  • 03:43:44
    so. All right. I can respond
  • 03:43:48
    to their comments, you know, and just,
  • 03:43:51
    you know, whoever submits them, we can create a small subgroup
  • 03:43:56
    or something and talk about it and
  • 03:43:59
    maybe have a solution next month.
  • 03:44:02
    So that'd be great. Okay.
  • 03:44:06
    Very good.
  • 03:44:11
    All right. With that, let's go to item 15, which is our combo ballot.
  • Item 15 - Combo Ballot - Vote - Eric Blakey
    03:44:16
    We have a few items that we've.
  • 03:44:19
    That we have placed on the combo ballot. This is for
  • 03:44:25
    ease, that we have one vote.
  • 03:44:29
    The intent and the desire is that everyone that votes will vote
  • 03:44:33
    in the affirmative if there's anything on this list.
  • 03:44:38
    And quite a few of these items are leadership votes. But we have a couple
  • 03:44:41
    of items that on tabling some NPRRs.
  • 03:44:47
    And then we do have the
  • 03:44:50
    endorsement of the 1D CMR. So I just want to encourage
  • 03:44:54
    everyone to take a really good look. Is there's any
  • 03:44:57
    of these that you were now having second thoughts
  • 03:45:01
    about and think we need to abstain or think you need
  • 03:45:04
    to vote against? It will not hurt anyone's feelings.
  • 03:45:07
    If you let us know, we'll take it off the combo ballot and we will
  • 03:45:11
    vote on it separately.
  • 03:45:14
    But with that, I'll see if we have a motion to approve the combo ballot.
  • 03:45:23
    Is 1232 going to WMWG?
  • 03:45:30
    No, we mentioned that as a suggestion,
  • 03:45:34
    and then we backed off and decided that
  • 03:45:38
    it would be better to keep that at WMS.
  • 03:45:41
    But WMWG has the option to
  • 03:45:44
    discuss at their next meeting, but we're going to keep that officially
  • 03:45:48
    at WMS.
  • 03:45:51
    Good question. Thank you. Any other
  • 03:45:55
    comments or questions on the combo ballot,
  • 03:46:00
    see David Dalych, motion to approve.
  • 03:46:04
    Very good. Second from Blake Holt. Any discussion on
  • 03:46:07
    the motion?
  • 03:46:11
    All right, I will turn it over to Brittany for the vote. Thank you.
  • 03:46:24
    Thank you. Blake. I have a message someone sent
  • 03:46:27
    me asking what happened to the CARD item. I don't
  • 03:46:31
    recall that we had a voting item under CARD.
  • 03:46:34
    Can anyone confirm that for me? I'm going
  • 03:46:38
    back up to. Yeah, that was the
  • 03:46:42
    discussion we had early on.
  • 03:46:46
    They were teeing it up for this meeting. We had a good discussion. And then
  • 03:46:49
    next month, they'll bring it back.
  • 03:46:53
    ERCOT and the imm and just any. Any thoughts they have in
  • 03:46:57
    the interim period, they'll bring that back and we'll. We'll discuss
  • 03:47:01
    direction our next meeting. Thank you.
  • 03:47:05
    I didn't see anything noticed, and so I just want to make sure nothing was
  • 03:47:09
    to be voting to waive. All right,
  • 03:47:12
    thank you again, Eric.
  • 03:47:16
    Here are y'all's eight items on the combo ballot you've
  • 03:47:19
    reviewed. And so we will begin with
  • 03:47:23
    the consumer segment. Eric? Yes,
  • 03:47:27
    sorry. Two Eric's today. Eric Schubert for Mark
  • 03:47:31
    Smith. Yes, thank you.
  • 03:47:37
    Yes, thank you. And Rick.
  • 03:47:41
    Yes. Thanks. Thank you all on the cooperative
  • 03:47:45
    segment. Blake,
  • 03:47:54
    we might have to come back to blake.
  • 03:48:00
    Blake, I see youre. There you are. I see you in the chat. Thank you.
  • 03:48:05
    Lucas. Yes.
  • 03:48:09
    Eric blakey. Yes. Thank you,
  • 03:48:12
    Brittany and Tim.
  • 03:48:16
    Yes. Thank you, Brittany. Thank you.
  • 03:48:19
    Independent generator segment. I believe Teresa Allen is not
  • 03:48:23
    with us, and I'll see if she has dialed in.
  • 03:48:26
    Teresa, are you here?
  • 03:48:31
    Okay, tom.
  • 03:48:46
    Tom Burke.
  • 03:48:50
    All right,
  • 03:48:53
    Andy. Yes. Thanks, Brittany. Thank you.
  • 03:48:58
    And, Brian, I see you have a
  • 03:49:02
    guess here in the chat,
  • 03:49:06
    and it was after Blake, since I'll seem this is for the vote.
  • 03:49:09
    Thank you very much. For independent power marketers.
  • 03:49:12
    Shane. For Reshmi. Yes.
  • 03:49:18
    Amanda? Yes. Thank you.
  • 03:49:23
    Robert? Yes. Thank you.
  • 03:49:28
    And Ian. Yeah. Thank you.
  • 03:49:31
    Brittany. Thank you all. Independent retail
  • 03:49:34
    electric provider. Anoosh for Bill. Yes,
  • 03:49:38
    please. And Anoosh. Yes,
  • 03:49:41
    please. And Joshua.
  • 03:49:44
    Yes. I don't believe
  • 03:49:48
    Amir is online, but in case he has dialed in. Amir, are you
  • 03:49:51
    with us?
  • 03:49:56
    All right, I removed Amir
  • 03:50:01
    on to investor owned utilities. David?
  • 03:50:04
    Yes. Ivan?
  • 03:50:08
    Yes. Brittany. Thank you. Jim.
  • 03:50:12
    Yes. Brittany. Thanks. And Vincent?
  • 03:50:16
    Yes. Thank you. All right. Thank you all.
  • 03:50:20
    Finally, municipal segment. David?
  • 03:50:25
    Yes. Ken?
  • 03:50:30
    Oh, Ken. I see your note in the chat. Thank you.
  • 03:50:33
    Curtis. Yes.
  • 03:50:36
    And Faye? Yes. Thank you.
  • 03:50:42
    Thank you all. Motion carries unanimously. Appreciate your help.
  • 03:50:47
    Great. Thank you for the vote.
  • Item 16 - Other Business - Eric Blakey
    03:50:51
    Okay, next item is 16 other business and review
  • Item 16.1 - Review Open Action Items - Jim Lee
    03:50:55
    open action items. Jim Lee, have anything?
  • 03:50:59
    Nope, nothing for me. Okay. Yeah, we sort
  • 03:51:02
    of covered it. I will just make a plug as we're
  • 03:51:06
    getting closer to year end reviews.
  • 03:51:10
    Just looking at the back of our agenda, there's a couple
  • 03:51:13
    items. There's, like, one open action item, and there's five parking
  • 03:51:18
    lots items. And they. They're all under
  • 03:51:21
    either WMWG or CMWG,
  • 03:51:26
    except for the EPA when we talked about it. Saab is also assigned.
  • 03:51:30
    So, anyway, I just encourage CMWG and WMWG.
  • 03:51:35
    You can get a chance to look through those and bring
  • 03:51:38
    back. Jim and I are very.
  • 03:51:43
    We want to keep on our list of ones we need to keep. And if
  • 03:51:45
    we. If they don't need to be there, if we want to request changes,
  • 03:51:48
    we can always do that. So I'm always
  • 03:51:52
    happy to take things off our list if we. We can.
  • 03:51:56
    Otherwise, we have no report from the CMWG
  • 03:51:59
    or MSWG. Is there anything else anyone needed to
  • 03:52:05
    add before we adjourn?
  • Item 18 - Future WMS Meetings - August 7, 2024
    03:52:09
    Okay, our next meeting is August 7. Hope to see you
  • 03:52:13
    there. We will plan to have an in person meeting next month.
  • 03:52:16
    Appreciate everyone's accommodation to make this WebEx
  • 03:52:20
    only. Again, want to shout out to CenterPoint and
  • 03:52:24
    the utilities in the south and east of Texas
  • 03:52:28
    to continue on their progress. And we know, let them know
  • 03:52:31
    that we're thinking about them and just really appreciate the
  • Item 17 - Adjourn - Eric Blakey
    03:52:35
    work they do. It's very important. So, anyway, with that,
  • 03:52:39
    we're adjourned. Y'all have a great day. We'll see you next month. Thank you.
20240710-wms-combined-ballot
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02-agenda-wms-20240710
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02-agenda-wms-20240710v2
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03-draft-minutes-wms-20240605
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05-weighted-lrs---peak-day-and-monthly_sample-calc
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05-card-reallocation---djm-ajr-rr
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05-as_provision_and_perfomance_related_to_insufficient_soc_report_template
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05-imm-card-disbursement-methodology-for-july-wms
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05-as_provision_and_perfomance_related_to_insufficient_soc_report_template_v2b
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06-wms_update_rcwg_20240710
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Meeting_materials_wms-20240710
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Meeting_materials_wms-20240710
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Revision-requests-wms-20240710
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Validation for WMS Standing Representatives - Pamela Hanson
Starts at 00:00:19
1 - Antitrust Admonition - Eric Blakey
Starts at 00:01:28
2 - Agenda Review - Eric Blakey
Starts at 00:01:52
3 - Approval of WMS Meeting Minutes - Vote - Eric Blakey
Starts at 00:04:17
3.1 - June 5, 2024
Starts at 00:04:21
4 - Technical Advisory Committee - TAC - Update - Jim Lee
Starts at 00:05:26
5 - ERCOT Operations and Market Items
Starts at 00:08:23
5.1 - Auction Revenue Distribution CARD and Calvin Opheim
Starts at 00:09:11
5.2 - CRR Balancing Account - CRRBA
Starts at 00:10:41
5.3 - IMM CARD Analysis - Andrew Reimers
Starts at 00:42:07
5.4 - Report template to track AS Provision & Performance issues related to insufficient State of Charge&lt;br /&gt;Luis Hinojosa & Sam Fabricant
Starts at 01:05:36
6.1 - RCWG Leadership - Vote - Blake Holt
Starts at 01:38:59
6.2 - Vice Chair - Kiran Sidhu, RWE
Starts at 01:39:06
6 - Resource Cost Working Group - RCWG - Blake Holt
Starts at 01:39:47
7 - WMS Revision Requests - Eric Blakey
Starts at 01:50:01
7.2 - VCMRR040, Methodology for Calculating Fuel Adders for Coal-Fired Resources
Starts at 01:50:05
7.1 - Impact Analysis - Vote - Eric Blakey
Starts at 01:50:11
8 - Demand Side Working Group - DSWG - Nathaniel Mancha
Starts at 01:51:26
9 - Supply Analysis Working Group - SAWG - Kevin Hanson
Starts at 01:57:15
9.2 - Chair Kevin Hanson, Black Mountain Energy Storage
Starts at 01:57:19
9.1 - SAWG Leadership - Vote
Starts at 01:57:42
10 - Wholesale Market Working Group - WMWG - Blake Holt
Starts at 02:12:21
10.3 - Vice Chair - Amanda Frazier, Treaty Oak Clean Energy
Starts at 02:12:42
10.1 - WMWG Leadership - Vote
Starts at 02:13:20
11 - Metering Working Group - MWG - Michael Blum
Starts at 02:15:42
11.1 - Procedure Update - Vote
Starts at 02:15:57
11.2 - BREAK
Starts at 02:18:48
12 - WMS Revision Requests Tabled at WMS - Possible Vote - Eric Blakey
Starts at 02:30:21
12.1 - SMOGRR028, Add Series Reactor Compensation Factors - MWG
Starts at 02:30:29
12.2 - VCMRR041, SO2 and NOX Emission Prices Used in Verifiable Cost Calculations - RCWG
Starts at 02:30:40
13 - New Protocol Revision Subcommittee - PRS - Referrals - Vote - Eric Blakey
Starts at 02:31:01
13.1 - NPRR1229, Real-Time Constraint Management Plan Energy Payment
Starts at 02:31:25
13.2 - NPRR1232, Standing Deployment of ECRS in the Operating Hour for a Portion of&lt;br /&gt;ECRS that is Provided from SCED-Dispatchable Resources
Starts at 02:46:41
13.3 - NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service
Starts at 03:12:15
14 - Revision Requests Tabled at PRS and Referred to WMS - Possible Vote - Eric Blakey
Starts at 03:19:42
14.1 - NPRR1070, Planning Criteria for GTC Exit Solutions
Starts at 03:19:46
14.2 - NPRR1200, Utilization of Calculated Values for Non-WSL for ESRs - MWG
Starts at 03:19:54
14.3 - NPRR1202, Refundable Deposits for Large Load Interconnection Studies - WMWG
Starts at 03:19:55
14.4 - NPRR1214, Reliability Deployment Price Adder Fix to Provide Locational&lt;br /&gt;Price Signals, Reduce Uplift and Risk CMWG
Starts at 03:19:59
14.5 - NPRR1219, Methodology Revisions and New Definitions for the Report on&lt;br /&gt;Capacity, Demand and Reserves in the ERCOT Region CDR - SAWG
Starts at 03:20:03
14.6 - NPRR1226, Demand Response Monitor - DSWG
Starts at 03:22:05
15 - Combo Ballot - Vote - Eric Blakey
Starts at 03:44:16
16 - Other Business - Eric Blakey
Starts at 03:50:51
16.1 - Review Open Action Items - Jim Lee
Starts at 03:50:55
18 - Future WMS Meetings - August 7, 2024
Starts at 03:52:09
17 - Adjourn - Eric Blakey
Starts at 03:52:35

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