05/07/2025
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- 00:00:53Hello, everybody.This is Blake Holt, and it's now 09:30.We'll go ahead and get started with WMS.I'm hearing an echo in the room.So if you have your your audio on, please please mute it or your microphone on.
- Item 1 - Antitrust Admonition00:01:09Before we get started, let's go ahead and pull up our antitrust admonition, and then I will get into the validation for our standing reps.Alright.Thank you for your attention to that.
- Item 0 - Validation for WMS Standing Representatives00:01:44Let's touch on our, representatives for today.Eric Goff with residential consumer gives his alt rep to Nabaraj for the meeting.
- 00:01:53In the cooperative segment, Joe Dan Wilson with Golden Spread gives his alt rep to Matt Welch.And in the independent retail electric provider segment, Bill Barnes for Reliant gives his proxy to Roozbeh.Alright.
- Item 2 - Agenda Review00:02:09That being said, let's go ahead and do a quick agenda review.First, we're going to review the meeting minutes from last meeting, and then we'll get into a few highlights from the most recent TAC meeting.
- 00:02:25After that, we'll move into a vote on our WMS strategic objectives, and then we'll we'll touch on item seven, which will be our longest topic for the day, which is the ADER phase three governing document.As we get into this, we'll have an introduction of the discussions at the last DSWG meeting from Nathan, and then we'll hear presentations from five interested parties on positions and red lines for the document.After that, we'll have a series of ERCOT reports and then get into our assigned revision requests and working group reports followed by any voting items that come out of those.At this time, is there any other, topics folks in the room would like to add to the agenda?Alright.
- 00:03:17Seeing and hearing nothing.
- Item 3 - Approval of WMS Meeting Minutes (Possible Vote)00:03:19Let's go ahead and pull up the WMS meeting minutes and do a quick review.I didn't receive any feedback, on these minutes.I'm curious if anyone on the phone or in the room, has anything of note to bring up.Alright.
- 00:03:46Seeing and hearing nothing, I I think this would be a good item to include on the combo ballot.Is there any concerns from the group with that?Alright.Thank you for that, Britney.We'll we'll leave that on the ballot for later.
- Item 4 - Technical Advisory Committee (TAC00:04:06Update) Onto our our TAC update, I don't really have much in terms of a TAC update, but I did wanna highlight that NPRR1229 and NPRR1271 were both discussed by this group and were subsequently approved by TAC.So I just wanted to thank, the working groups and and reps for for the work on those topics, and did wanna highlight that we'll likely have a firm fuel supply service expansion update later in the agenda with, NPRR1275.Alright.The next item on the agenda are the WMS strategic objectives.I'll give Britney a chance to bring those up.
- Item 5 - WMS Goals/Strategic Objectives (Vote)00:04:54Jim and I presented this to the group last month, to give you a preview and and asked for red lines or or any ideas.In the interim, I haven't received any.I'm curious if any in the room or on the phone, have any opinions on these strategic objectives.Combo ballot.I think this is I got a thumbs up for Brian.
- 00:05:23He really wants this on the combo ballot.Any concerns from the group if we do that?Alright.Perfect.We'll we'll vote on those later.
- 00:05:39And then now on to, the demand side working group.I didn't see a report posted, but wanna give Nathan a chance to to give a verbal update if needed.Nathan, are you on the line?
- Item 7 - ERCOT Operations and Market Items - 9:55 a.m.00:06:04I don't actually see him on the line, so we'll we'll skip that for now, and move to, number seven, ERCOT operations and market items.
- Item 7.1 - ADER Discussion – Phase 3 Governing Document (Vote)00:06:15The the first topic we're gonna get into is the ADER discussion.
- 00:06:20And before we we jump in, I just wanted to thank all of y'all for your engagement on this topic.There has been quite a bit of discussion, between stakeholders and ERCOT offline, that that folks have involved us in.So just wanted to say, we appreciate that engagement.Ultimately, thank engagement and debate is how we get to the best decision at this group, and we're going to see some of the latter today.We've had five parties express interest in in giving presentations on their thoughts on the governing documents.
- 00:06:56We have some red lines to also go over, and so we're gonna grant those folks some time to to make their case.Haven't really given a hard cap for presentation links, but would like to ask that, folks be efficient and, be mindful of time as they're going through their presentation.And for the group, we're gonna hold off questions during each presentation and and wait till folks have finished to for efficiency purposes.And we'll we'll kinda just go through, the topic like that.I will say that there have been some parties that have posted information and materials to the meeting, but did not request time to present.
- 00:07:37I I would welcome them to hop in the queue after the fact, but we probably won't have a full blown presentation from y'all.Once comments kinda wrap up, what we'll be looking for is a, a vote on a concept to send to TAC.I've spoken with market rules a bit.We don't necessarily need to have red lines perfect.During this meeting, we can do that, between now and TAC, but I would like to to vote on a a concept to move forward.
- 00:08:09And those are sort of the ground rules that I have for the conversation.I'm curious if any in the room or on the phone have, comments or suggestions there.And so, I guess to start off with, Ryan King, would you like to give a a brief introduction on the topic, or would you like to just kinda get into presentations?Thanks very much, Blake.I think I might just yield to the discussion here because I think, at the last WMS, we kinda noted where the, the contentious or nonconsensus, maybe I should put it, items exist.
- 00:08:47And it sounds like we have a fairly fulsome agenda for discussion today.So I will kinda yield the time for, those stakeholders to make the presentations.And if I have questions or comments, I'll just join in the queue.Sounds like a plan.I I still see Nathan is not on the phone with us.
- 00:09:03I do know that there was a conversation at DSWG about the, non instances items, but I I think, like you said, that that'll play out, as we go through these presentations.So I think we can move forward to the presentation from Leap.Colin, are you on the phone?Can you hear me?Yes, sir.
- 00:09:27Go ahead.Awesome.
- Item 7.1.3 - Leap Presentation00:09:29Thanks.And thank you everyone for providing me the opportunity to present at this wholesale market subcommittee meeting.I'll be speaking on the, value of third party participation, or, I guess, the participation of third party aggregators in in.
- 00:09:46I know we have a packed agenda, so I'll go ahead and dive right into it.So jumping on to the next slide.I first wanted to give a quick introduction to myself, and to the company I represent, LEAP.My name is Colin Smith.I am the regulatory affairs manager at LEAP, which is a demand response aggregator.
- 00:10:06We operate the way that, you imagine an aggregator would.We aggregate a number of smaller devices into, one larger resource that is then sold, or up you know, then sells grid services into wholesale markets.If you jump to the next slide, you can see sort of a little visual representation of how this works.The, primary way in which we operate perhaps a bit differently than some other third party aggregators is that we operate on a fully partnership based model.We don't enroll in customers ourselves.
- 00:10:42We primarily, or we explicitly partner with DER technology providers to help them connect their customers to wholesale markets and other demand response programs in their region.And I wanna point that out because, one upshot of that is that, you know, in venues like this, when we provide feedback, we, do our best not just to represent, you know, our own interest, but the interest and views of the different technology providers, that we, partner with.So jumping on to the next slide, a quick visual, of where we operate.Leap is active in deregulated markets, across The US.In, ERCOT, we are particularly or specifically active in the ERS program.
- 00:11:29We are not yet, active in ADER, and I'll get into a little bit of detail as to why that is, in later in the presentation.But jump to the next slide.I wanted to quickly give a bit of a visual representation of the types of companies that we partner with.Won't spend too much time in this slide, but just wanted to, give a sense of the scope of different partnerships that we, have, and the range of sectors that our partners work across.We work across partners in all different technology classes from smart billing technologies, to EV charging and battery storage.
- 00:12:04In Texas, we primarily work with smaller resources.Think residential batteries or smart thermostats, would be our our primary sort of, partnership base, that we do work with C and I customers, in other, regions as well.So that's it for the introduction.I wanted to provide, you know, as much time as possible to get into the content of this conversation because I know there's a lot to say.We have had some presentations at past wholesale market subcommittee meetings, about some concerns about allowing, third party aggregators to participate in ADER more directly than they currently are able to.
- 00:12:45I want to give a bit, lead a discussion on, the other, sides, provide some, details about the value and the benefits that third party aggregator participation could provide both to ADER as a pilot program and to, Texas customers as a whole.So jumping to the next slide, so we can do exactly that.First, setting the stage a little bit, I wanted to take a step back and look at, you know, what we are trying to accomplish through this pilot.Reliability is a a a key goal.Many of us are aware that in the wake of winter storm winter storm Uri, there was a concerted effort by, ERCOT to integrate more DERs into its marketplace.
- 00:13:30This was exclusively called out or explicitly called out in ERCOT's roadmap to improving grid reliability reports, which identified a need to eliminate barriers for demand response to participate in ERCOT's marketplace.That's exactly what the ADER program is designed to do.It, provides a pathway for DERs to participate in various ancillary services, in the ERCOT marketplace, through aggregations.Its success so far has been mixed.Adar had a goal of meeting, you know, getting 80 megawatts enrolled in the program that identified in its phase one.
- 00:14:07We're now moving into phase three.I believe we have about 25 megawatts enrolled in the program.So still not quite halfway there.And the ADER governing document, was very explicit in its intention to expand overall participation in the program.So there's a clear goal here to, to scale the, ADER program or increase the scale of the ADER program, so it can provide more services to the Texas grid.
- 00:14:37But scale alone is not not necessarily the only goal.Speed is also an important dimension here.And to see why you don't have to do anything other than look at some of ERCOT's recent recent modeling around expected load growth in the, Texas power grid or on the Texas power grid.Recent modeling suggests that load will nearly double in Texas by 2030.So we don't wanna spend several years fiddling with the of a pilot program.
- 00:15:06As, you know, the needs on taxes to grid grow exponentially, we really want to be able to, expand the program as as rapidly as is feasible to make sure that we can start integrating these resources into ERCOT's wholesale market to allow them to start providing grid services as quickly as possible.And another key point that just sort of underlies all of this that I I wanted to discuss is competition.You know, I don't have to, explain to anyone here how ERCOT has successfully introduced more competition, to the electricity sector than any other state in, The US or, I ISO in The US.And Texas has done this to the benefit of customers.And I think that it's really important to emphasize that point.
- 00:15:53You know, competition is very rarely good for all companies, in a particular sector.In fact, most companies, when, given a choice, would prefer not to be exposed to more competition.But it's important to, have competition because competition benefits customers.And that's why Texas has worked so hard to create a fully open and competitive marketplace and electricity sector to provide benefits like lower costs and increased choice to customers in Texas.And I really think that framing is important to keep in mind as we continue the discussion about how to expand the ADER pilots program going forward.
- 00:16:31So jumping to the next slide, still in a bit of a stage setting, phase right now, but I think it's important to provide some context on the discussions on this particular issue, because there have been a number of them, and not everyone on this call I know has been privy to them in the past.So looking way back to, October 2022, we have, the the date when the current aid or governing document was approved by ERCOT, October eighteenth twenty twenty two.This, approved document used a participation model that treated ADERS as aggregate load resources under the ERCOT protocols.What this means is that customers participating in ADER implicitly were required to participate in ADER through the same QSE that provides retail electric service to their premise.That's a rule for ALRs under the ERCOT protocols, and so it was also implicitly a rule for customers participating in theater.
- 00:17:40Fast forward to, August year, commissioner Gothel T.Filed a memo specifically calling out this QSE matching requirement as a barrier to expanding the ADER program.His memo called out that the 80 megawatt goal had not yet been reached.It is important to understand the barriers to expansion and specifically ask the task force to look at if it is possible for consumers to select a VPP provider that is not their electric retail provider, a retail electric provider to see if it is possible to remove this QSE matching requirement.And that's sort of where a lot of this started.
- 00:18:16That is why this QSE matching requirement is such a area of discussion because it was specifically identified as a barrier, to expanding your participation in the past, and efforts have been ongoing to see if and how it can be removed to allow the program to scale.And that's exactly what ERCOT did in response to commissioner Gottfelty's memo.The, ERCOT, proposed in September of twenty twenty four a new participation model in ADER modeled after the non controllable load resource model.This NCLR model, was kind of specifically identified by, ERCOT as not requiring or the QSEs, it participating in either to be matched.Specifically, ERCOT identified that in the NCLR model currently, the QSE representing a resource does not have to be the QSE representing the premise or the electric provider as the load serving entity.
- 00:19:18So if this new model was introduced into the governing document as is, it would implicitly not have this QSE matching requirements, and so was responsive to commissioner Vlafelty's memo.However, if we jump to the next slide, you can see that, there was subsequently a response by retail energy providers a couple months later.A group of, reps, consisting of Octopus Energy, Vistra Shell, and Base Power Company filed comments, expressing concerns about removing this QSE matching requirement and requesting that the governing documents kind of specifically, input language to keep this QSE matching requirements in place.This led to some back and forth with, the the different stakeholders in the task force.The task force held several ad hoc meetings in late December of last year, eventually arriving at a compromised solution, which would allow premises that had a a total load above a hundred kilowatts, to participate in ADER through a third party QSE.
- 00:20:26This compromise has been called a couple of different things.In the last demand side working group meeting, it was referred to as option one.I personally call it a Christmas accord just because of the timeline in which it was worked out.But the kinda upshot of this compromise, was that it was, identified to be an interim compromise.Most people are aware, that the ADER program is not really focused on resources above a hundred kilowatts or I should say customers would load above a hundred kilowatts.
- 00:20:58It's really designed to aggregate smaller resources into larger re or smaller, devices into larger resources that can be offered into ERCOT's, marketplace.There aren't really that many customers above a hundred co ops participating in ADER right now.That's not really it's it's kinda target, customer.And so having a hundred kilowatt threshold was, in a lot of ways, akin to not allowing third party QSE participation at all.The reason this compromise was developed was specifically to limit, third party QSE participation at the outset so that the program could get more experience with third party QSE participation and expand it going forward.
- 00:21:45And in fact, the, revised governing document that ERCOT released after this compromise was reached specifically identified a goal of addressing any additional barriers needed to be removed in order to allow for broader third party QSE participation in ADER, in order to, you know, get, maybe the the, to move towards the goal that, was initially identified.So, moving finally into the current year, we had a another change.Sorry.We're still on the last slide.There's a lot of context.
- 00:22:23But, a new, memo by the PUCT moved aided discussions, to the general ERCOT stakeholder process.This was done according to the memo, partially to allow for more rapid growth of the pilot, once again emphasizing the need to, expand this pilot quickly.That's not, necessarily what it what has happened so far.Last month in April, in this wholesale market subcommittee, meeting, in the last meeting of the subcommittee, VISTRA, proposed a, made a new proposal, in this, meeting, revisiting the, Christmas accord compromise that was worked out last December.In this proposal, they, kind of proposed that the compromise be eliminated, or amended with additional conditions.
- 00:23:17This has been referred to as option two in the past.I referred to it as the VISTRA amendments just to keep it clear, that it is an amendment on the original compromise.And that's finally, you know, catching us up to where we are right now.I'm currently in the process of revisiting the compromise that was worked out last December, so that we can move the pilot forward.Alright.
- 00:23:38Jumping to the next slide, finally.I appreciate everyone, sitting through, that, bit of history, but I do think it's important to understand kinda how we got to where we are.I also think it's equally important to understand why we're spending so much time talking about this.And the reason why this is important to work out, is because third party aggregation provides the most scalable model for DER market participation in ADER and in general.You don't need to look outside Texas to see this.
- 00:24:08You can look at the ERS program, that ERCOT, manages, which provides, up to 1,000 megawatts of load reduction across 24,000 sites of a large of, including, smaller resources, like smart thermostats, residential batteries, exactly the types of devices that ADER is targeting.And this load reduction is largely provided by third party aggregators.The reason why the third party aggregator model is, kind of dominant in ERS is because third party aggregators' business model is specifically designed to enroll customers en masse in these programs.They're able to do this because they can work with all customers of a specific DER provider or technology allowing for rapid customer acquisition and enrollments.You know, customers can be enrolled at the point of sale of a specific technology by their DER technology provider.
- 00:25:01They can be, contact through Outreach via specialized, customer apps related to these technologies.You know, there are a number of, tools and strategies that third party aggregators, have developed to, enroll customers in these programs quickly.And I think one of the biggest and clearest proof points of this is that to date, the main participant in ADER has been a retail energy provider that is also a DER company, just talking here specifically about Tesla.Companies that LEAP partners with, alone expect to have 80 megawatts of potential capacity in 2026, which would be a significant boost to, the ADER portfolio.But this, these resources won't enroll in the program if the QSE management requirement is kept in place.
- 00:25:54This is because participating, DERs through customers' load serving entities creates a prohibitively large hurdle to the enrollment process.A DER aggregator or a DER technology provider would need to partner and contract with 20 to 30 different reps and their associated QSEs if they wanted to enroll their entire portfolio through the existing model.There are just tons of different reps in Texas.Contracting partnering with all of them is a a lot of time, and effort and time and effort for, aggregators and and Doctor technology companies is money.And these enrollment campaigns are already very challenging to, put into place, working through such a diverse landscape of reps in order to enroll their portfolio has meant that most, DER aggregators have just not participated in to date.
- 00:26:48In addition, becoming a rep is a complicated, and expensive process that, you know, based on our discussions with our partners, very few, DER technology companies or aggregators have interest in doing.So that's kind of where we are right now and, why this, barrier continues to hinder participation in the ADER program overall.Jumping to the next slide, we can look a little bit at sort of where we go from here.So LEAP believes that, you know, with some adjustments, the proposed compromise, is a promising first step to over time, expanding data participation by removing these barriers.Looking first at the hundred kilowatt threshold compromise that was worked out last Christmas, we, at LEAP, are happy to hold to this compromise for phase three.
- 00:27:42We recognize that it was sort of a a majority position by the task force.We do believe it creates an opportunity to, test out third party QSE participation in.So we're we're happy to keep it for phase three.But it's important to also continue assessing ways to expand third party participation past this threshold in the future.We're optimistic that the concerns that have been raised are very addressable and could be worked out in time for third party QSEs to participate at scale in 2026.
- 00:28:17But the key element here is really just that there remains in the governing document, for ADER a recognition that, ERCOT is intending to still, continue to look at ways to expand third party participation and pass this threshold.Participating in a program like ADER is not a small investment.You know, technology companies and aggregators need to, make, you know, operational changes, and, reach out to customers to, get them enrolled in this program well ahead of the point where they're actually participating.It will be difficult for, these third parties to, justify the these time investments, without some understanding that there is an effort, underway at ERCOT to, eventually remove barriers to them participating.So being able to point to language in the governing documents saying that these, this is a goal and these issues are still being looked at is important to, make sure that these companies, kind of have the the, at least directional certainty they need to be able to make these investments, in the near term.
- 00:29:31Personally, we think that this, compromise already represents, enough of a a solution to move forward with for phase three.However, we do recognize that Vistra had a number of other concerns, and we are, you know, happy to look at those as well, as we understand, that they have, you know, responsibilities to their customers as well.So I I I've included the primary two here.First, requiring ERCOT to verify that there is a relationship between the third party QSE and and the LSE.We're happy to keep that, as a requirement that, you know, the, rep be notified if one of their customers is participating in ADER.
- 00:30:14You know?We we think that that it's important for reps to be able to know when their customers are participating in a program like ADER, but we want the process and the information that needs to be provided to the rep to be very clearly defined.And over time, either in a phase four or, you know, as the program is, eventually expanded past the pilot phase, we would, expect that this, kind of notification system would need to be streamlined or this process would need to be streamlined.You know, there are there are many more reps than DSPs.It would be a significant administrative burden for ERCOT and for everyone else to, kind of have to verify, a a ton of different, kinda, agreements between QSEs as this program scales up and more, QSEs are participating.
- 00:31:07So we think it's important to streamline that over the long term to reduce administrative burden for all involved.Finally, I'll end on, the other, amendment that district put forward, the ability for either QSE to terminate a customer's enrollment in.We would recommend that this particular amendment not be included in the final governing documents.This is a significant barrier to third party QSE, participation in the long term.It would be very difficult for third party aggregators to justify the investment of enrolling customers in ADER if it's possible for a potential competitor to terminate that customer's enrollment in the program unilaterally.
- 00:31:52We also don't see it as necessary either now or over the long term.In the near term, the 100 kilowatt threshold already keeps participation in ADER via third party QSEs quite low.So you don't expect there to be a significant, you know, concern there in the short term.And even on the long term, it does not seem like this is something that, is, critical.You know, as I mentioned, reps are not DSPs.
- 00:32:16You know, there's not, like, grid safety requirement that might, force them to terminate a customer's enrollment in ADER.The only reason I can think of why a third party or sorry, why a rep would, kinda, need to move to terminate a third party customer's enrollment in ADER is if there are some concerns about customer protection violations by the third party QSE.Customer protection measures are important and something that is already called out in the governing document as a barrier that needs to be worked out in order to expand third party QSE participation in the program as a whole.And so that we we would suggest that if there is ultimately a requirement, or an, ability for either QSE to terminate the customer's enrollment in ADER, that this be tied to very explicit criteria around customer protection.And, so that third party QSEs can, have a clear understanding of the conditions under which a third a a rep would be able to, unenroll one of their customers from the program.
- 00:33:26So that is everything that I had to say.Thank you for your time, and I'll I'm happy to, cede the floor to the next presenter.Thanks, Colin.I don't see any questions or comments in the queue.Appreciate the background you gave, and just wanted to give notice to the rest of the group.
- 00:33:46To the extent that your presentations have a little bit of history in there, I think, you know, Colin's given us a good good coverage of that.So that's probably something you can skip in your presentation.And I think going forward, we're gonna hold presentations to fifteen minutes just giving notice of that.So next next up to present is Voltus.Do we have a rep from Voltus available to go through their presentation?
- 00:34:13Yes.I'm here.
- Item 7.1.2 - Voltus Presentation00:34:13This is Kimaya Abreu, and my colleague, Youssef Shaker, is also on the line.So good morning, everyone.I am a regulatory affairs manager at Voltus.
- 00:34:24Thank you so much for this opportunity to present.Our presentation follows, closely from Collins, so I will try to skip some repetitive content.We are here today to offer a proposal to move forward on the question of non LSE participation in ADER and the parameters around it.And and before I get into this background slide, I just wanna state our goal here, with this proposal, and and that is to recognize that third parties really have the expertise to grow Adar and bring megawatts to to market in.And if if if we want the program to to to reach its potential, we need to make sure that there are not barriers to third party participation.
- 00:35:09The option two that Vistra presented at the last WMS, in our opinion, does make it difficult for third parties to play, and and that's why we're here today presenting another option.So, quick background, what we're seeing on this slide.I think what I wanna highlight here is this chart on the right, to show that ADER in its three years, has seen slow growth, and that's partly due to a lack of pathways for third parties.So the lines on the bottom show show ECRS and non spin participation, maybe something to to about 20 megawatts.And the participation limits are for phase two and phase three, forty and eighty megawatts respectively, for specifically ECS and nonspin.
- 00:35:50The limits are are are higher for energy.But, basically, we can see that there's a a lot of growth to to realize that potential and meet those caps.Next slide, please.And next slide.Yeah.
- 00:36:02Thank you.There's been discussion about a status.You can go back one.There's been discussion about a a status quo, in phase two, which was that restriction of third parties.To highlight something Colin said, that restriction, is really a function of the model that existed in phase one and phase two.
- 00:36:25For instance, the controllable resource model explicitly has that QZ matching requirement, but there was no explicit language.There is no specific language in the Next slide.It's it's still the same slide for me.Hey, Kamaya.I think we're having some technical difficulties.
- 00:36:54Hold off for a bit, and we'll get this done.Okay.Sure.Thanks.I'm in I'm in go go rush mode to to, try to get this through this content quickly.
- 00:37:04So, sorry for the double ask.We may be back.Is that the slide you were looking for?That's perfect.Yes.
- 00:37:15Thank you so much.Yes, ma'am.Great.So meanwhile, the status quo under the NCLR model, which is what which is really the main innovation of of phase three is to is to bring in that NCLR model and allow for for blocky aggregations.The status quo under that model is to allow third parties to participate, and and third parties have been doing so since the early two thousands.
- 00:37:39So as was discussed extensively at the task force and presented by ERCOT, to bring in the NCLR model, but add an LSE consent requirement, you know, or or or stronger as was suggested in in VISTRA's presentation at the last WMS would really imply a carve out or exception to ERCOT's standard way of doing business today.And our concern is that the carve out or exception adds administrative work for ERCOT, in managing that program.Administrative work that we understand there's there's sort of, limited capacity for given given everything that's that's going on on the demand side given RTC+B, etcetera.A carve out or exception increases program complexity and ultimately limits the scale and scope of potential ADERs.Next slide.
- 00:38:33And so to highlight a couple of additional points from the history here, Colin gave a much longer history, but I'll just start in December in this second bullet point.ERCOT presented actual phase three red lines at that task force meeting, and those red lines explicitly stated that there would not be a QC matching requirement that sites could participate through a QC that's not the same as their LSC.Of course, there was recognition of debate around this issue at that point, and and rep concerns.And so the compromise that was developed to allow those those third parties to work with sites over a hundred k w, was extensively discussed and voted on.It passed by a super majority of 17 to four, where that super majority included some reps.
- 00:39:22So the compromise that was sent eventually from the PUCT to ERCOT at the beginning of twenty twenty five, represented extensive discussion across a whole range of stakeholders from TDSPs to ADER providers, ERCOT co ops or reps, and is a really strong starting point, for for a path forward for third parties.In fact, in our view, is still the most effective and simplest solution for bringing third parties online while respecting concerns.I'm going to pass it next, to my colleague, Youssef Shaker, to talk about specifically, some concerns that were raised so we can move to the next slide and move to Youssef.So, in this section of the presentation, we wanted to discuss, three of the concerns that Vistra raised.Just to summarize what these concerns are, the first is that, ADER participation would result in changes in load shape that would, affect the hedging strategy of reps.
- 00:40:25The second is reputational risks associated with ADER participation with third parties for reps.And then the third one is consideration for participation for smaller customers smaller than a hundred k w, in the long run.So to start off with, the load shape concerns that, Vistra raised as it pertains to hedging, we thought the best, way to explore this, concern is through, an example.So here we have an example of a large commercial customer in the figure on the right large residential customer, I'm sorry, in the figure, on the right.And this is what their load shape would look like without any intervention.
- 00:41:11Now if we move on to the next slide, we consider their participation in, ADER via, smart thermostat curtailment, that occurs in the early evening hours.What I wanted to mention here is that the impact is actually quite minimal as you can see.And this curtailment would actually only happen, you know, if if they're in ECRS, it will only happen once a year, if not less, based on historical data.And, actually, that curtailment would be beneficial to the rep in terms of their hedging position because the curtailment would occur in the high price hours, which would be financially advantageous to the rep.But what I what I want to further highlight, if we move on to the next slide is right now, customers can make all sorts of changes to their load shape, and their energy consumption without requiring any rep consent.
- 00:42:09For instance, consider that same customer, installs an EV in their home.This is something anyone can do.No one needs to email or message their rep about that change, and they consume electricity that looks very different, in a way that looks very different and actually increases their electricity consumption by, in a very large way.If we extend this argument to, industrial and small commercial sites, you could you could imagine an industrial site going down because they have, equipment issues.Again, they don't need to tell their rep that that that happened when they changed their electricity consumption.
- 00:42:50Or you could consider if they take a longer than usual summer break, for instance, that would really change their electricity consumption.Again, they don't need to notify their rep.However, we do hear their rep's concerns that it would be advantageous for them to know when the customer is enrolled in either in case they need to make any changes to the hedging strategy.And as a result, we agree with a compromise to notify the rep of cost customer enrollment either without necessarily requiring consent.And that's, a compromise that we believe allays some of the rep's concerns with regards to, changes in customer, consumption.
- 00:43:30If we move on to the next slide, another concern raised by Vistra is reputational risks associated with participation, in either.And we want to emphasize that the this is the reason why the hundred k w cutoff was introduced at the task force level, in that customers larger than a hundred k w are more sophisticated energy consumers such as big box stores that have a very holistic strategy for how they're consuming electricity and therefore would would really understand who's dispatching them for what.And as a result, we do support the, the utilization of the hundred k w cutoff, in the short term until further discussions, around customer protections and so on occur through the pilot.And that brings us to the last point, which is, concerns around, in the next slide.Sorry.
- 00:44:32Concerns around, consideration of broader participation in the future.There was language in the governing talk about, including, considering the inclusion of smaller customers in the long run, which, which was removed by Vistra.We believe that this language should be brought back.As as Colin, mentioned earlier, we we believe that these are a lot of very valuable megawatts to the ERCOT grid.And with the, consideration for how we can include those in the future, we're really leaving a lot of megawatts of flexible demand on the table.
- 00:45:08We we think this should be included, but perhaps without the the the reference to the timeline in order to allow task for to allow the pilot, participants to to have more time to discuss the details of that.I will hand it over back to Kimaya to discuss, the path forward, VCMRR.Thanks, Youssef.So moving to the next slide, and you can keep going one more.I want to emphasize again something that Colin discussed and has been brought up in this presentation that third parties today are really critical to bringing DERs to ERCOT programs.
- 00:45:45And specifically, as a data point, if we look at ERS in the 2025 winter season, a full 80% of the 1,400 megawatts in the program were provided by non rep Queasies.So for ADER to grow, it is essential to bring in those third parties, in a in a robust way.Looking at the next slide, we can kind of consider some ways in which, Vistra's proposal, option two, might limit participation by third parties.And our our key concern here is that the consent requirement is essentially a veto power, over a consumer's participation in ADER.One issue is that there might be a competitive relationship in some cases within a certain set of reps and a certain set of third parties, that, you know, could could impede a smooth, customer choice, between third parties and reps given this sort of veto power, in that in that termination ability.
- 00:46:52And a second issue is that, you know, for all sorts of reasons, a rep might, you know, ideologically, or or just administratively, you know, when you when you think about the requirements of of signing that consent form, be resistant to allowing customers to participate with third parties.And in such a case, if the rep itself does not offer an Adar program, the those customers, will not have a pathway to participate in Adar, which means leaving valuable, flexible megawatts on the table.So with this in mind, next slide, we have a couple of recommendations.The first recommendation is really to lean on option one, that well negotiated task force super majority compromise.That compromise means bringing NCLRs into without requiring any changes or new requirements in the ERCOT managed processes.
- 00:47:49And we hope our presentation today has has made clear that some of the concerns that were previously raised about option one, you know, over the last, month or so are actually already addressed by the features of option one itself, particularly that 100 kilowatt threshold that addresses, consumer protection concerns, and the the cap to the program, I should say, when we're looking at a program that in phase three, is is capped at at 80 megawatts for ancillary services.The the the hedging risk or the effect on load shape across all all reps is, is is limited, and and Youssef also explained, how there are all sorts of other things customers can do that would have a much bigger effect on on the hedge.Option one also represents the simplest path forward, from an an administrative perspective.But in recognition of reps' concerns, we'd also be comfortable with an option two b, and Voltus and Leap have collaborated on red lines and and a form that were posted, to the meeting page today, or posted a few days ago and are up there today.And this option two b is a notice requirement in lieu of a consent requirement, under which the Queasy would provide to the LSC with sufficient time, something like forty five days in advance, we're suggesting, Details of all the premises served by the LSC that the Queasy is attempting to register in the ADER that it's developing.
- 00:49:19ERCOT would receive an that notice and attestation from the LSC.And, you know, we're we're we're more than comfortable with this notice requirement, but do want to note that it it does require an extra step for ERCOT to, manage and and hold on to those notices and attestations when in NCLEAR participation today, there's there's no such level of oversight.In this appendix in the next few slides, you know, we've we've highlighted, screenshotted some of our red lines, but I'll let us reach those in questions and and pause there for now.Thank you.Thanks, Kamaya and you, Steph.
- 00:49:59Just wanted to flag to the group that those red lines are posted in the meeting materials.And am I correct, Kamiyah, that your option two b on the the previous slide summarizes those red lines?That's exactly right.Yes.Okay.
- 00:50:18Good deal.Thank you.You do have a few questions in the queue.I'd like to start off with Bob Whitmire.Well, that was careful timing, wasn't it?
- 00:50:29My question was, was careful consideration given in this presentation to the use of the word LSE versus Rep?LSE includes NOE's where Rep does not.So, yeah, that's my question.We've been a bit loose with those terms.I think that's a fair point, but I think the notice requirement would would apply to to Noeze as well.
- 00:50:58Youssef, let me know if you have a different, take.Yeah.I I think Noeze have the exclusive right to serve all load in their area, so that could be an issue.Thanks.Yeah.
- 00:51:08No.Let me add something here is that, under existing rules as as you, mentioned, Noiz would need to approve any customer participation.And I think there we we're not proposing any carve outs for, Noeze to be able to, to approve such participation under those rules.I'm sorry.So you're saying that Noeze would need to approve it or would not need to approve it?
- 00:51:39So as far as as far as I understand, according to your standing ERCOT, nodal protocols, NOEASE would have to approve any any participation, but, like, not necessarily under the terms of of the pilot just as a as a general rule.Yeah.Any any QSE offering service in their area, they have to approve.Exactly.Yeah.
- 00:52:01Thank you.Yep.Yep.Thanks, Bob.Next in the queue is Roozbeh.
- 00:52:11Thank you all.First of all, I wanna appreciate all the, presentation by Leap and Voltus.And also specifically wanna call out and appreciate Leap's understanding that the, queasy to queasy coordination is is important and should be kept.We appreciate that.What I wanted to call out is specifically on both this presentation.
- 00:52:32Couple of points.I know I'm gonna forget the second point probably, but, I think that it was a very good slide.There was one slide specifically calling out the load shape.I think it it looks like a residential customer.I think it was called out to be residential.
- 00:52:47Just just to give folks some idea, you know, as as the rep or load serving entity, you are the risk manager on behalf of the customer.And a lot of times, specifically related to the point that was made that, you know, you know, if there is a deployment of NCLRs, the lowest curtailments will be beneficial to the rep.That's not necessarily true.The reason being is it's not just what happens in real time from deployment that matters.It matters what matters more is the expectation of this kind of capability.
- 00:53:27Like, reps manage things on a forward basis all the way.The risk from forward forwards all the way to flow to day ahead to real time, short term markets.And they worked very hard to make sure all the drivers, you know, are forecasted accurately, and there's a good expectations of them available.So all the load forecast models are worked on very hard to have those predictions in them.In this specific example, you could have, you know, to give you a number in day ahead.
- 00:54:00For example, you're serving a residential customer.You go to short term markets.Weather is hot.You procure more supply.Day ahead clears very high.
- 00:54:13And the rep not knowing that this capability of curtailment exists, it's procuring at expensive day ahead prices.You go to real time, the next day, price is high, but lower than day ahead.And then there's deployments.You still had economic harm.Just to give you a very simple example to tell you that the expectation matters and that query to query the coordination really provides the very important data points to enable the rep to at least do some creative anticipation of modeling of this kind of capability.
- 00:54:51Yeah.And and I was gonna hear sorry.Sorry.Sorry to interrupt you there as well.Please go ahead.
- 00:55:00No.I I was gonna say I'm until you recognize some of these dynamics, and and that's why we we still include, a notice requirement.But to your point, I'm I mean, I I I I totally understand where you're coming from.But if you compare this to the status quo where there would be no curtailment in in real time, like, there's no change to the strategy that you would take as a as a rep.Like, the the strategy you'd follow knowing that they could curtail in real time is one that's more economically advantageous to the one to to the one so, like, let's take the example.
- 00:55:40If, like, if the customer is not participating in either, you would continue to procure energy in day ahead in the example you mentioned.And that's what you'd be doing now.Now in the case that they're participating in ADER, if you're able to take that into account, you'll be able to save money on your hedging.However, that's that's an added benefit that, like, you're not necessarily making use of in in the status quo.And I in the long run, if you if you know and understand that this customer is participating in either via the notification requirement, you could always modify your hedging strategy to to take that into account.
- 00:56:20And having said both of those points, as as I mentioned, I think what we're trying to highlight more in the slide is that all sorts of customers, especially larger ones, could make very, like, significant changes that result in hundreds of megawatts and change of of their load shape way bigger than the limits prescribed by this program without notifying their reps.So we understand that this information is valuable, but as far as the status quo goes in terms of what information is communicated to reps, we don't see this as a huge departure from from, from what occurs now.But, yeah, I mean, totally agree that more visibility is better and that we're we totally agree, hence the notification requirement.Sure.And and then that's fair.
- 00:57:07And and I'll just add, you know, just two more minutes.I know you had a long agenda here.So quick two points on on what you just mentioned.You know, first first name, other you call something normal course of business, and those valuabilities could be even larger than the potential deployments.It's it could be true.
- 00:57:28But, But, again, those normal courses of business, in case of residential, and let's just talk about both residential and commercial industrial.Residential is weather, mainly, or it's EVs or assets.Right?In terms of weather, lots of variability, but, again, you do a great job of having creating expectations for them and do have a great forecast for it.I mean, the scenarios around it.
- 00:57:50EVs, we use telematics.You have tools in place again to model that and know who has an EV, who that.And, again, expectations is what matters.So so yes.That's one piece.
- 00:58:01In terms of industrial commercial, there's still coordination depending on the contract you have in place with the customer and the type of business they're on.There's still coordination with the pricing desk, you know, maybe not 200%, but there is some in place.And just last points, I'll leave you with this.I think you made a good point.If you assume status quo is no way that exists, maybe there is some benefit to the curtailment and deployments.
- 00:58:27But, again, remember, you are contaminating the data that feeds our forecasting model by deployments.That contamination, right, over time, a great model could learn that, but it takes time.Right?So you are contaminating.You're curtailing at hour and twenty for the summer.
- 00:58:46You're showing a lower peak over time.Our model might understate that forecast.You know?So you're starting to get a less and less accurate forecast on until we get to a point where there is enough data that our models can learn this correctly and predict it the right way.That's why this coordination is so important.
- 00:59:05It gives us some sort of data ahead of time until we kinda generate enough historical data.Thanks for Yeah.Well, Youssef, we're gonna move forward to the last comment, on on this presentation.Dave, would you please go ahead?Hi, Blake.
- 00:59:22Yeah.Thank you.And I'll I'll try to keep it quick.And would you mind going to slide 18 in the appendix, Brittney?And I apologize for for not catching this earlier.
- 00:59:34I was reviewing the the language and the presentations, and and I understood the broader concept, but there were some changes to, some of the language up above that was a little less specific to the the proposal you all laid out in terms of the the two options.I was wondering if you could just talk a little bit about, the changes you made on on this page and sort of what what what some of the intent was.Sure.And and, yeah, we didn't quite highlight it on our recommendation page, but this is the point about bringing back, the the policy recommendation to consider in phase three other types of of participation, including participation with smaller customers.So a key point, we we took the original language from the task force bullet, and made some additions as you can see.
- 01:00:26One of them is to remove the timeline requirement.So the, original bullet had sort of a a the the point this would be considered by the end of of the current q two.So there's there's now no reference to timeline.I'll actually pass it to Colin to talk a little bit more about the specifics that were added, whose intent, as I understand, was was to add more specificity and clarity on what should be considered.Yeah.
- 01:00:53Thanks, Kimaya.Yeah.I I do I do wanna say that this is this, bullet here is not a separate component from the 100 kilowatt compromise that is referenced at other points in the governing document.This bullet here really was part of the initial compromise.It's the sort of area in the governing document where it sort of explicitly recognized that the hundred kilowatt compromise was an interim solution, and some that's, ERCOT intended through the pilot to continue to look at opportunities to expand third party participation in the future.
- 01:01:33This bullet is in a section of the governing documents titled policy questions for consideration.A number of the other bullets, as you can, you know, kinda see here a little bit, also look at other items that are, connected to, you know, ongoing changes or improvements to the program.The changes made to this bullet in this move in q two were really just some an effort to kind of make the, intention, of ERCOT to address the, threshold, that 100 kilowatt threshold a bit more clear, a bit more explicit.You know, none of these are really so critical, but it just, you know, made sense to, kind of, you know, if the this bullet was was meant to be a point where, ERCOT looked at potentially broadening participation of third party QSEs in the future to, you know, clean up that language a little bit.I think maybe you're also referring here to the the changes to the alternative telemetry requirements.
- 01:02:35That's another, I I would say, barrier to large scale participation in ADER that is not, you know, we're not currently kind of addressing in this conversation.I think in this this particular bullet, that that bullet was just quite short, and we thought it made sense to, kind of, edit it to kinda call out why that bullet is important, and, what it could mean for participation in ADER if alternative limiter requirements were investigated and, approved.Yeah.Not nothing, I think, game changing in either of these.It really is just meant to sort of clarify, and make more explicit some of the reasons and, intentions Collin, I hate I hate to cut you off there.
- 01:03:27Dave, I wanna make sure.Was your question answered?Yes.It sounds like it's it's more about just what what we should be considering in the future, and and trying to see some more specificity of that from the point of view of of Leif and Voltus.So if that's helpful, and, hopefully, my volume is better.
- 01:03:43I heard that it was a little bit low before.Thank you, Blake.Thanks, Dave.Thank you.I'd like I'd like to move forward on to the the VISTRA conversation.
- 01:03:52And as they're getting set up, I I see Nava Raj is in the queue.Nava Raj, do you have a quick comment?Yeah.Just a very quick first of all, thank you very much, Colin and Himaya and, Youssef for for the detail, presentation.Your concerns are very valuable.
- 01:04:14And just a quick concern, regarding I represent residential and a small commercial consumer in Texas.So very quickly and very shortly, can you tell me how does your proposal language sense will be beneficial for residential consumer?Very simple.Short answer.I think the the simplest way to describe it is just this would allow more, residential customers to participate in ADER and get the benefits of that participation.
- 01:04:53Okay.So just a little bit, different way what, Vistra proposed.We'll we'll hear more from Vistra shortly, but, if if you want to say, here are the barriers they are proposing, and here are things we are doing it.This is how it will benefit to the residency country.But if, very simple language, you have anything you want to say, I mean, you can tell that.
- 01:05:30Thanks, Nabaraj.Just quickly Go ahead and finish.Yeah.Thank you.Just quickly adding, you know, Colin mentioned more residential participation with this sort of policy bullet and looking forward to phase three.
- 01:05:43When we look at phase two and the hundred kilowatt cutoff, you know, obviously, there's there's no resi involved, but the benefits to to our red lines, for residential customers in phase two is is really expanding, growing ADER to its full potential and providing, grid reliability benefits, to to everyone, including residential customers, and also proof of concept of third party participation and a pathway forward that would then allow, you know, the the the the kinds of partnerships that that Colin discussed and that that Leap does, with, smart device companies, to to bring more residential customers in in a further phase.Thank you.Thank you.Alright.Thank you all for for y'all's presentation.
- 01:06:33I'd like to turn the floor over to to James, with Vistra.Thanks, Blake.
- Item 7.1.4 - Vistra Revisions01:06:41As you guys pull up my my presentation here, my name is James Langdon from Vistra.Thanks for the opportunity to come back to WMS today and present.And thank you to Voltus and Leap for their presentations as well.
- 01:06:58Our principal issue here is a lack of coordination with reps when participate as NCLRs.To alleviate this concern, Vistra has joined Enchanted Rock, so we really appreciate Enchanted Rock, working with us on this, and coauthoring, this proposal, which was discussed at, DSWG last month.Namely, parties coordinate for the benefit of the customer.You can go to the next slide.And you could yeah.
- 01:07:35That's perfect right here.Our proposal is a simple one.Leap laid out the long history and hard work that's led to the what was called the Christmas Accord.We appreciate that work, that went into that compromise, and our red lines retain the task force recommendation for sites greater than a hundred k w.We simply add that element of coordination.
- 01:07:57The concept we're introducing here is an LSE acknowledgment form that mirrors the DSP acknowledgment form that already exists.Just as ERCOT verifies the relevant DSP has signed off on the ADER, ERCOT will use this new form to verify that the LSC's queasy has signed off as well.A signed form allows ERCOT to quickly and easily verify that a queasy to queasy relationship exists between the LSC queasy and the third party queasy.At the last WMS meeting, there was a good amount of discussion around cross settlement, LMP minus proxy dollar g.This solution avoids that complexity entirely.
- 01:08:39This is important because ERCOT does not have the capacity to take on a complex administrative roles, for a pilot like this.Next slide.So, here you can see that the new LSC acknowledgment form simply mirrors that DSP acknowledgment form that already exists from phase two and, I think, phase one as well.Next slide.There was just some discussion about this bullet.
- 01:09:10Vistra has kind of always recognized the pilot nature of this program, and the section four bullet here represents a significant level of effort to resolve, issues that we see around customer protection, rep notification, other permissions.And for this reason, we've always, had this eliminated from our our our red lines, just to allow ERCOT to wrap their arms around the program as it is before we start, moving into, requirements that they look into, other elements.Other edits down below simply align the LSC acknowledgment form that we're introducing with the rest of the phase three governing document.Next slide.I'll point out here in section five c one, we propose adding a couple columns to the, details of the aggregation form, the DOTA, which simply mirror the columns that are associated with the DSP acknowledgment form.
- 01:10:10So just further alignment here.And, next slide.So section five c six outlines that, you know, what the LLC acknowledgment form does, just as the DSP acknowledgment form does in section five c one.So a lot of the same language.This isn't a huge, adjustment or a huge change.
- 01:10:37We just, our section here eliminates some of the technical details on the controllable device, certifications, etcetera.And, that's the end of our presentation, kinda keeping it short.Just some final comments.You know, Voltus expressed concerns that, reps may not reply to an LLC acknowledgment form or if they do terminate early without cause.As a rep, look, we're committed to our customers and the solutions that they demand.
- 01:11:08Any rep that doesn't partner with third parties risk losing valued customers who have expressed interest in data participation.Again, parties coordinate for the benefit of the customer.Thank you.Any questions?Thanks, James.
- 01:11:23A few questions in the queue.I I do see that Monica jumped in, so I'd I'd like to give her a chance to speak, and then we'll get to the rest of the queue.Thank you.Monica, please go ahead.Hi there.
- 01:11:33This is Monica with Enchanted Rock.I just wanted to echo, some of the things that James mentioned.We did come up with these red lines together and, you know, obviously supportive of them.We think that this is, a workable path forward for phase three of the governing document.That being said, Enchanted Rock specifically is not necessarily opposed to the, proposals put forward by by Voltus.
- 01:12:02And so, you know, we would be supportive if there is a compromise in there that could be, reached.However, these red lines obviously, work for us considering we, helped, put them together.So that's it for me.Thanks, Monica.Thanks.
- 01:12:21Next up, Brian Sams.Hey.Good morning, everyone.Brian with Calpine.First question, I wasn't a participant in the ADER task force at all, but, was there ever any kind of discussion that, if a customer enrolled in one of these, it would be an opportunity for the rep to reprice their retail contract?
- 01:12:47I don't think I think the the the contracts that reps have with their customers, you know, are take privacy here.So we're not you know, we would have to then adjust a cost a customer's contract to include some clause that if you enter any of these other arrangements, then we have the right to change.But I don't believe that exists as it stands now.Okay.Just curious about that.
- 01:13:13But that might be a topic for another discussion.Just I I also wanna talk about, like, process and what what's expected of WMS today, because there's a lot of content here.And so just like, Jim, like, what what are what what are your expectations for success for WMS today?Yeah.And I I tried to touch on this earlier today, and and so my understanding from TAC and from ERCOT is that they would prefer a decision from WMS at this meeting on a concept to move forward.
- 01:13:48And so the idea today was to present all of the concepts that are on the table Yep.And for WMS to endorse one of those concepts.That's the happy path.I think TAC doesn't meet till the end of the month.So if there's an opportunity to to seek further compromise between now and then, I think there's opportunity for that.
- 01:14:10But, that is my goal for WMS today.Just just my observation from our discussion is, there are several options, and no matter what we choose, someone is gonna be unhappy.And so, I I would be happy to make a motion to endorse the VISTRA proposal.And, folks, if there's a second to that, we can vote on that and move forward.If there's, people don't like that, they can appeal it, but at least gets us moving the right direction based on what you laid out.
- 01:14:45Appreciate it.We have a motion on the table.I I don't think we need an immediate second right now, but I also want to check with Ryan Keane to make sure that I've laid out the correct timeline and expectations for for WMS today.Yep.Yep.
- 01:15:00Yep.Thank you, Blake.Alright.We have a few more in the queue.First up, Catherine, do you do you need to speak immediately?
- 01:15:13Or okay.I'll I'll go to Andy first.Yep.Quick question.This is for ERCOT.
- 01:15:22James spoke about the low administrative burden relative to some of the other proposals.Can you validate those comments that this queasy to queasy attestation that merits the DSP would be, less administratively burdensome?Well, I I think that excuse me.The the point here is it's not no administration.But it it seems to be it seems to allow a level that ERCOT would be comfortable with because, essentially, we are looking at the form the attestation that has been submitted and relying on the coordination between the other parties.
- 01:16:03So, in the spirit of that, we we would be okay with that or something looks like.I think there is one point that that Catherine wanted to raise, with respect to this.So I'm okay to kinda yield to Catherine if she wanted to raise this now.Sure.And your question is a good segue into my monologue about customer, privacy issues.
- 01:16:24So and I, had a chance to talk with James about this before, but under the VISTRA proposal.So if a, QSE for an ADER has customers from multiple different reps, we would want to make sure that, that entire DOTA form isn't just sent to each of those reps because, a rep who is not representing that individual ESI ID shouldn't be getting that customer's information.So if a individual ADER is made up of, say, customers from 10 different reps, the QSE for the ADER would need to break those 100 customers into different packets and send it to the just the appropriate LSC to get their, LSC acknowledgment form.So, I think if the VISTRA proposal was what was what we moved forward with, there'd need to be some additional red lines to what they've proposed because we need to make sure we have an LSC acknowledgment form that's appropriate for each of the batches of customers.Does that make sense?
- 01:17:34So that is, that is a little bit more administrative work than what for the d, DSP form.We just get one DSP form, for that entire ADER package.This would be we need to make sure that we are tracking those 100 customers, for example, and that we have an LSC form that corresponds with all of those customers.And we wanna make sure that the language is clear in the governing document that the QSE for the a ADER needs to make sure that they're only sending the customer information to the rep of that customer.And I think, under the VISTRA perp I'm sorry.
- 01:18:21Not VISTRA, Voltus proposal.It's less of an issue, but we I think that that language would also need to be tweaked just to make sure that if instead of an affirmative consent by the rep saying, yes, this customer can be in the aider, we would need to, if instead it was just a a program where the aider just sent the notification, hey.These are the easy IDs that are in this program.It needs to be made clear in the governing document that, the QSE for the ADER needs to be only sending customer information to the appropriate LSE for that notification.So it it again, I think what Ryan said is it it is, under either one, it's a little bit more work for us, but it's something for a compromise.
- 01:19:15We're willing to if a compromise can be reached, we're willing to go ahead and, do that work.If I could, yeah, if I could just comment real quickly, I think there's yeah.You would need an LSE for each rep that is involved.Our proposal does add the column in the DOTA, which allows you to have a check mark saying that, yes, this is there.So you're kind of looking down.
- 01:19:40When ERCOT receives the full DOTA, they'll have for each ESI ID that's in the list, they'll have a a check saying, yes, there is a signed LLC acknowledgment form just as there is a check mark for a signed DSP acknowledgment form.Okay.I appreciate the additional information.With that, I'm happy to second the motion.K.
- 01:20:04Nathan, are we are we clear on the the motion or need any clarification there?Good to go?We have the motion from Brian, first and then second from Andy.So we'd still have some additional red lines to discuss.I'd recommend we we get through those and then, proceed from there.
- 01:20:22But, Ryan, I did see you raise your hand before we get back to the queue.Would you like to add anything?Yes.Sorry.This is a this is a very small item, but there are a handful of what I would call very minor administrative edits that we'll probably need to make to the governing document.
- 01:20:38Most of them pertain to the fact that this, this governing document is no longer with the the PUC and the task force.It's under the ERCOT stakeholder process.So I just wanted to note that, if there is a motion today and a vote, if we can do it under the basis that we would be making these very small tweaks, That's just kind of Absolutely.I'm probably getting mixed up in procedure here, but it's kind of a Yeah.And I've had a discussion with Britney.
- 01:21:07I've been trying tried to be careful that we were just voting on a concept and that any, you know, tweaks that need to be made in in the interim can can take place.Let's quickly through work through the rest of the queue, and then we'll move on to the, Tesla presentation.Now, Barash?Yeah.I think I'm asking the same question what I asked, earlier for the third third party.
- 01:21:32So my question to Hishra is how you guys better represent residential customers, number one.Number two, I think, the third party we're talking about the customer protection things.So tell me how you guys better protect customers.And then lastly, well, the the I think they talk about the 80 megawatt barriers.The, so can we just briefly talk about that barriers as well?
- 01:22:11Is that, something, a rep is not, is it not in the in that barrier process?I mean, are you guys making, holding that eight eighty megawatt?I mean, like, you know, if we see the total megawatt, it's like a very, very low, right, dimension in that point.How you address that thing?So these are my primary concern.
- 01:22:40Thank you.I I think I missed the first point, but I'll go to the other ones I did here, which was that, a rep has significant customer protection rules, and, you know, that is exactly why it's expensive and and burdensome for somebody like Leap to become a rep because we have to comply, with a lot more rules in PURA than a third party aggregator does.So the burden is on us to ensure the customer is protected, and, and we, you know, take that responsibility very seriously.On the third question about the limits, we were happy to endorse the, expansion of the limits that were resolved in the Christmas accord and, don't have any edits to that in our red line.The first part, I I missed, though.
- 01:23:35Oh, the first part was, how residential customers will be benefited, from a rep perspective better than what they already discussed, from the third party.Are you guys better?I mean, why why you guys are better?Just simple.I think it's just the the coordination, making sure that there's a relationship between, you know, these third parties and the rep.
- 01:24:08I think that if there's less confusion from the customer's point of view on who's controlling their their load, that is a a a good thing.And so sometimes, you you know, in this accord, the hundred k w floor was assumed to be a proxy for sophisticated customers.But, you know, we see that that's not always the case.And so we want somebody who is part of one of these on the NCLR, side to be aware of how their load will be managed and not to confuse who's who's controlling it, the rep or the third party.And as long as there's coordination and communication, we think that the customer's, interest will be served.
- 01:24:51Thank you.Thank you.Alright.We're gonna cut off the queue after Jim Lee, but we'll work through the rest and then progress in the agenda.Kamaya?
- 01:25:02I just wanted to briefly ask I actually think this has maybe been touched on, but is there any difference, in ERCOT's perspective, in terms of administrative burden with with the notice with the proposed notice requirement and and, taking as a as as proof of coordination and attestation, from the that, the, that that the rep has been brought into the conversation.This is Catherine.I can talk about that, Ryan, if you want, and then you can chime in maybe.I so I think if I heard the question you are asking of the VISTRA versus Voltus, which one is more administratively easy for ERCOT to implement?And so I think under the Voltus proposal, since all we're looking at is an affidavit that those customers were actually, I'm thinking through it.
- 01:26:15It might be the same amount of work, actually, because we will need to track that under the proposal that we have a affidavit or something, to attest that a certain batch of easy IDs, within the ADER have a corresponding attestation, from the LSC that they receive notice.And under the VISTRA proposal, we're we will similarly have to track that we have a LSC acknowledgment for each group of easy IDs for that LSE.So I think that it's probably the same amount of administrative work.I don't know, Brian, if you think differently.Nope.
- 01:27:00That I agree with that.Thanks, Catherine.Next up, Jim Galvin.Thanks, Blake.Can you hear me okay?
- 01:27:08Yes, sir.Great.Thank you.And I'll be quick.I'd my intent was to second the motion, talk a little bit about customer protection.
- 01:27:17But thanks to others, those have already been done.We're very supportive of having something go forward for the pilot.The concern that I'm gonna eventually have is is we're talking about this concept of a third party QSE that really isn't defined by ERCOT protocol.My concern on getting on board with this long term at some point is going to be granted, we're talking about administrative versions to ERCOT, but eventually, that's gonna come at a cost.And for a third party QSE of this sort, any costs related to administrative fees and or potential uplift of market charges related to whatever comes out of this program is something that would not be assigned to those directly under the current settlement mechanism.
- 01:28:03So I it's gonna be hard to get to a point long term that's gonna agree to have third party or technology participation in the markets without them also sharing the burden on the cost that we would incur as participants.We designed this market for a a premise to have a single LSE of record.When we start expanding that, I can see additional complications, and then all of a sudden, LSEs or reps subsidizing the cost that others are benefiting for.So that's the general point of my comment.But again, the primary is second the motion.
- 01:28:39Thanks.Thank you, Jim.Next up, Colin.Thanks.A question on the red lines.
- 01:28:55Colin, you may have dropped.Are are you still there?Yes.Can you hear me now?Yes, sir.
- 01:29:07Sorry about that.A quick question on the red lines put forward by Vistra.I didn't hear any discussion in this present Yeah.Colin, you're you're breaking in and out.If you could, please just write your comment in the queue.
- 01:29:27Let's see.Alright.Okay.Sounds good.Colin, you're breaking up.
- 01:29:34Can you can you just please put your question in the queue, and I'll I'll I'll ask it for you?Sounds good.I'll go ahead and do that.You can move to Jaylee then.Sounds good.
- 01:29:42Jim?Thanks, Mike.Jim Lee with CenterPoint.This is more of a question for Catherine.You had could you help me regarding the agenda rock recommendation, can you help reiterate the impacts to the DSPs when we're completing DSP acknowledgment?
- 01:30:02I I didn't read any changes to that, but you had mentioned something earlier about having to do different different validations.I maybe I confused the the issue, but currently, like, an 80 an an individual ADER has to all be within one DSP's area.So, what I was saying is, like, if an ADER wants to be in Centerpoint's service territory, they just need the DSP form from just CenterPoint, and that's it.But under the VISTRA proposal, because the customers might be represented by various different LSCs, then the QSE for the aider is going to have to make sure, that they're gonna get LSC acknowledgments from all those different LSCs, and that's a little more complicated than just getting the one DSP acknowledgement form just, like, from CenterPoint, for example.Yep.
- 01:31:08I think that's what I Okay.You so you had mentioned LSC and then d s DSP.I'm I'm I'm there's still one disconnect there.Sorry.From the rep.
- 01:31:20Yeah.So you might have to get, different acknowledgments from different reps.Okay.So the QSA would have to get different LSA acknowledgments, but still Still just the But the DSP acknowledgement remains unchanged.Right.
- 01:31:34Right.Yeah.Okay.Alright.That's right.
- 01:31:35Thank you.Mhmm.I appreciate that.Thanks, Jim.I'll I'll have more work.
- 01:31:41He's fine.I'll read Colin's comments in the queue, and I think I think they're both pointed to you, James.Does Vistra's current set of red lines still include the ability for either QSE to unilaterally remove a customer's ADER verification?Just as the DSP acknowledgment form does, it allows for a thirty day, bilateral termination clause.So we just mirrored that.
- 01:32:07And just to be clear, we wouldn't expect that a rep would be abusing that privilege.And then file finally, noting that we're voting on principles here, does Vistra have any objection in principle to the bullet point on expanding third party participation in ADER in the future?I think from our perspective, we wanna respect the ADER task force.I mean, there's there there was some I think the compromise was allowing for that to be a kind of forward looking statement, And our preference would be just let's let ERCOT, get their hands around this program, and potentially look at that in the future.But right now, we were opposed to that.
- 01:32:58Thanks, James.And and seeing a clear queue, we have one more presentation from Tesla.
- Item 7.1.5 - Tesla Revisions01:33:04Would like to give Eric Goff, a chance to present his proposed red lines, and then we'll move forward with the motion on the table for a vote.Good morning, everyone.Eric Goff today on behalf of Tesla.
- 01:33:24We have some proposed red lines, not a presentation, that accomplished two things.One, that's a a minor, a relatively minor request that we think is straightforward, and the other one is related to the cap on the on the program that we think is a significant issue.So I'll get to the easy one first.Right now, there's a the pilot allows for some but not all, of ancillary services to be in the pilot.And there are good reasons to explore and and, you know, question how to do these other ones.
- 01:33:57They're they're more significantly involved in the in the operations of greater than less of like an uncertainty product.But, there are devices, including Tesla's, that can easily and and do easily provide these services on the markets.So we think this is a resolvable problem.We just like to have a path to identifying how to provide these services in phase four.There's been a lot of discussion about retail, that we're not getting into, in this presentation.
- 01:34:27But from the perspective of retailers, one of the benefits of being in this program is, that you can buy answering services from your customers.So being able to buy all of your answering service and not some of them helps to to provide that access.So this is at one point, we make another similar edit, to, what to do in phase three specifically later on that's in substantially the same edit.I'm happy to talk about that before I get to the cap if you don't have any questions.But, hopefully, this is a relevant some of our request is to further explore how to do the programs without some specific requirement about what to do about them.
- 01:35:09Okay.So in regards to the cap, Tesla, has kinda long called for, you know, having broad participation in this market and in this pilot.Hopefully, the actual we won't need a pilot at some point soon, and we can get past this, without a cap.Initially, for phase one, ERCOT, proposed a very small cap, that we compromised on in this at the level we are now.And the proposal here involves doubling the cap on on the the participation of the program.
- 01:35:50I I wanna inform people that the existing cap, is insufficient for Tesla's existing customers and is blocking participation, in this program because, the we've we've hit the internal cap.There are multiple caps in this program, including internal participation by one, participant.Doubling that number, is insufficient.There is unserved demand from Tesla's customers.And and, frankly, without having a clear understanding of whether these barriers will continue to exist or not, the company has to question whether participating in the pilot is worthwhile or not, and, you know, may, determine that it it's not worth it if we don't remove the caps.
- 01:36:44This is a direct, imposition on our ability to serve customers, and, the existence of the cap will directly inform Tesla's participation in the in the program.We hope that we can remove the cap altogether, and and that's what we're advocating for.So as I think everyone knows, Tesla was instrumental in establishing this a this ADER pilot through the efforts at the commission.And I think me describing this commercial situation should be impactful to question whether or not, the cap serves a public purpose, or if it's, you know, getting in the way of competition.And I'm giving you these statements seriously and, you know, with due concern for the success of the pilot.
- 01:37:39So for for those reasons, we hope that we eliminate the cap.I'm happy to take questions.Thanks, Eric.This is Blake Holt with LCRA, and I'm gonna call my card first.And this question is for ERCOT.
- 01:37:55I'm hoping you can give us a history on, the necessity for these caps.Was there operational concerns, or or where did that, what was the genesis of that?And I see, Ryan, you're in the queue, so maybe you have some comments you could fill in the gaps for us there.And all are y'all opposed to this change is the other question I have.Thanks.
- 01:38:16Thanks, Blake.And, thanks very much, Eric.I would say to to your first point, just wanna remind folks this is a pilot.So pilots almost by their nature have some form of scope related to them.The pilot is fundamentally about understanding, learning, and I would say evolving.
- 01:38:36And so what we have tried to do through this process is we started with, an initial cap of, 40 megawatts as was discussed.In the second phase, we expanded the participation of the services that, ADERs could provide.So we initially had a a non spin AS participation.We expanded that in phase two to, allow for the ECRS.And in phase three, we're proposing to not only expand the participation model, but also double the cap, to, 80 and a 60 megawatts respectively for ancillary services and energy.
- 01:39:20So, maybe to to to respond, we would we would oppose, completely removing the caps.I think it undermines the the the basis of this pilot.I think ERCOT said, on other occasions that we would look as a long term goal to make this part of our, enduring market design.And then at that point, we would, you know, the need for caps and some of the, other parts of the pilot would probably go away.But this is still a pilot.
- 01:39:51It's administered entirely.There's there's no budget for this.This is administered entirely through ERCOT's existing resources.We also need to, make sure that this is manageable in terms of the registration that we receive and the, ability to manage this pilot in addition to the other responsibilities that ERCOT has.We also have noted, and I believe this is in the governing document, that we would, provide some discretion to increase QSE limits in addition to system wide limits.
- 01:40:22So we would be responsive to those concerns raised by Tesla.In fact, in in our initial cut at the governing document, we proposed to remove those QSE limits, but it was actually stakeholders themselves that wanted those retained.So, hopefully, that addresses some of the concerns that, ERCOT would have, for the pilot of this phase.Thanks, Ryan.Next up, Brian Sams.
- 01:40:49I think Eric wanted to respond.I I appreciate that.Tesla's been clear for years and participated in this pilot that there are fixed costs to operating, in the in this pilot program, and, we appreciate that it's a pilot.Frankly, as it relates to NODS and ECS, I question if there's anything else to learn in the pilot phase and that we can move on to an actual market.The, those fixed costs, are born through participating in the program, and, we're not operating as a charity, in order to to, you know, run the pilot program.
- 01:41:36At at some point, we need to allow for participation to be commercially viable.And and we're telling you that from our perspective, that point is now.Brian?Well, first, I'm very sensitive to your comment about recovery of fixed costs.We've had lots of discussions about that in this forum.
- 01:42:01Yep.So that's a good point.You know, to your second point about the the cap, I heard you say that Tesla agreed to the cap when we were setting up the the pilot years ago, and we have since grown, well above, that.We have customers at Tesla that are able to participate in the pilot physically, but can't because of the cap.And so there's an actual real world barrier to participation right now.
- 01:42:37So how how does the pilot end?I mean, that's what really what you're questioning is is this end the pilot.Right?Or or at least for the purposes of what the way Tesla interacts in the pilot.There may be other things to learn related to non controllable load response that we've talked about within the governing document.
- 01:42:56There's still some real lessons to learn within a pilot context.But from the perspective of how do home batteries provide non spin ACRS, I think it's an answered question.Yeah.Well, maybe the the right answer for that is at the commission for a petition to end the pilot.Just thinking out loud here.
- 01:43:16I don't I don't think we'd wanna end the pilot for other people that wanna learn lessons from that perspective, but we can take some of the initial questions.We can say the pilot has answered these questions, and there are other questions to be answered through ongoing pilot activities.K.That that's helpful for I'm thinking about just your issues generally, but I'd I'd think maybe the expansion of the pilot is, maybe we're not there yet, or maybe it's it's for something for the commission to answer.I I appreciate that.
- 01:43:56And I think, you know, one way for WMS to address these questions, would be, you know, to without necessarily endorsing Tesla specific changes, to tell TAC that, you know, we TAC and the board should identify whether there are barriers to participation caused by the cap.And that we don't have to give them the specifics, but it tees up the question.Yep.I'd I'd support that question.And happy birthday, Eric.
- 01:44:22Thank you.Happy birthday, Eric.I see a clear queue, but not a moment too soon.Dave has jumped in.Dave, would you like to go ahead?
- 01:44:38Yeah.I feel guilty now.I hit enter right as you said that.But I I just wanna no.I I I appreciate Eric's presentation and all the presents today presentations today.
- 01:44:51I I guess I did just wanna emphasize something that, Ryan already spoke to.But as we, you know, have these conversations moving up to the tech level, to the board level, that one of the things that we wrote into the governing document right up front was this discretion without an approval of the new governing document to expand the system wide limits in response specifically to some of the issues that Tesla has raised and sort of a compromise to our original proposal going into phase three to fully eliminate the QSE level limit was to add discretion there too.So, you know, I think there is a there is a a lot more comfort on our end considering the degree to its that this is creating barriers, particularly after the doubling of of the limit.So I think in the very short term, I think that does provide some liberal belief, but having a limit with our discretion to make sure that we can administer the program makes us a lot more comfortable than just fully eliminating the caps.Thank you.
- 01:45:58I appreciate that complexity, Dave.And, you know, I've tried to be pretty clear in the implications of this decision, you know, in my communication today.And I understand, you know, y'all are having to work within a broad context.Perhaps between now and TAC, if you all can describe the way that you would exercise that discretion to, alleviate, Tesla's concerns, that would be a productive use of our time that we could inform TAC about.Sounds good.
- 01:46:34Thank you.Okay.Alright.We have two more in the queue, and and then we're gonna get to the boat.Youssef and Kimaya, I'll give you all the last words.
- 01:46:46Thank you.Sure.Thanks a lot.So in the absence of consensus around the red lines, I know folks have seen our presentation, but also there's been comments, submitted by TABA as well as NEP.I think there's a large set of concerns here that really put the success of this pilot at risk.
- 01:47:12We think because of that lack of consensus, maybe it's appropriate to push this decision maybe for a month or so and search for consensus specifically around the issue with, you know, allowing, reps to to basically, terminate as well as, withhold participation of their customers in, in ADER.So, yeah, just just putting it out there that we think maybe it's more appropriate to to push this forward, or punt it, for a month or so.Thanks, Youssef.Tamaya?Yeah.
- 01:47:57Thank you.In in particular, I think VISTRA's and and Enchanted Rock's proposal contains two very significant, changes from the task force compromise.One is this consent, you know, veto ability, termination ability, and the second is removing that policy bullet points about considering, smaller customers.And, you know, there's there's been this this discussion on both and, alternate proposals and and now some some red lines from Tesla additionally.So so there's a lot on the table.
- 01:48:34I'll say that there have been efforts offline to reach consensus up to this point.VISTRA, has presented the same red lines that that that were presented a month ago or or or the same proposal.What we have tried to do is, respond to to their proposal and, you know, our option to be as a compromise between what was already the task force compromise and what was proposed last WMS.So we feel like we're we're we're moving in the right direction and and that the additional offline time could get us there as opposed to endorsing, you know, a significant deviation on on at least two points from the task force compromise today.So that's that's really the request, to to give some time to consider everything that's been presented and the comments as well, to to make sure that what moves forward, is is comfortable to a range of stakeholders, including third parties who will, hopefully be bringing a lot of these megawatts online.
- 01:49:37Thank you.Thanks, Kimaya.Last word for Colin.Thanks.This is Colin Smith from Leap.
- 01:49:45I second what Youssef and Kimaya said.I I believe that there was a call to move forward with a vote sort of in the spirit of compromise and moving the the pilot forward.I'm concerned that, the, VISTRA red lines, would not achieve that.There's probably not a consensus, around the VISTRA red lines.There's a lot of concerns that we've voiced about, you know, where this would take the pilot.
- 01:50:09Now I understand there's concerns on both sides.I think that, you know, to the extent that the vote moving forward was the vote was done sort of in the spirit of compromise, then a more appropriate next step would be to delay the vote so that more time can be had to reach that compromise.And there's already been a number of kinda offline discussions between the different parties.You know, I think that those could continue, and we could eventually arrive at something that would be, more of a consensus position, one that, moves the, pilot forward in a in a direction that makes the most sense for for everyone.Thanks, Colin, Youssef, and Kamaya.
- 01:50:51I appreciate your comments.Speaking for WMS, we we do have a a motion and a second on on an option, on a concept, ready for a vote.So my preference would be to to see what, the will of WMS is, through the vote.And I would also just like to highlight the opportunity to, communicate concerns to TAC, by the end of the month.Happy to to assist y'all there.
- 01:51:18But my preference now would be to continue with the vote.It looks like Britney has brought that up.And so whenever you're ready, Britney.Thank you, Blake.This is to endorse the ADER phase three governing document concepts as described in the VISTRA Enchanted Rock proposal.
- 01:51:39We'll begin with the consumer segment.Rick?No.A barrage for birthday boy, Eric Goff?Yes.
- 01:51:50I'm sorry.I didn't hear you.Yes.Thank you.K.
- 01:51:58Preeti?Yes.And Mark Smith?No.Thank you all.
- 01:52:08Moving on to the cooperative segment.Blake?Yes.Lucas?Yes.
- 01:52:17Jim?Yes.Thank you, Britney.Thank you.And Matt for Jodan?
- 01:52:23Yes.Thank you.Independent generator segment, Teresa.Let's see.Teresa Allen.
- 01:52:40I see you in, logged in.If you're having, mute issues, you can answer in the chat.Brian?Yes.Thank you.
- 01:52:50Andy?Yes.Thanks, Brian.And Tom?I believe Tom is with us today.
- 01:52:58Teresa, thank you.I see your response in the chat as a yes.Moving on to independent power marketers.Amanda?Yes.
- 01:53:09Thank you.Ian?Yes.Thank you.Shane?
- 01:53:13Yes, ma'am.Thank you.And Robert?Yes.Thanks, Britney.
- 01:53:18Thank you.Independent retail electric providers, RUSPA for Bill?Yes, ma'am.RUSPA for Bill?Nope.
- 01:53:36Thank you.I see you in the chat.Joshua?Thank you.I see you in the chat.
- 01:53:44Austin?Yes.And Ruzba for Ruzba.Thank you again.Onto the investor owned utility segment, Jim.
- 01:54:04Yes.Thanks, Britney.Ivan?Yes.Thank you.
- 01:54:08David?Yes.And Rob?Yes.Thank y'all.
- 01:54:13Finally, municipal segment, Curtis?Yes.Mike?Yes.Ken?
- 01:54:22Yes.And Faye?Yes.Thank you, Britney.Thank y'all.
- 01:54:29The motion carries 90% in favor, 10% opposed with zero abstentions.Thank you, Britney, and thanks, WMS.Let's take a well deserved break and return at 11:35.Thank you.There we go.
- 02:04:14Hi, everyone.This is Blake giving a one minute warning.Anyway, it's And we'll start back up with the q one settlement stability report.Alright.It's November.
- 02:05:30Magie Shanks, are you available to walk us through this report?Yes.I'm here.Alrighty.Go ahead.
- 02:05:36Okay.
- Item 7.2 - 2025 Q1 Settlement Stability Report02:05:37So my name is Magie, and I'm part of the ERCOT Settlements Group.And this is the q one twenty twenty five settlement stability report.So for this quarter, we had no, price changes that occurred after settlement statements have been posted.Next slide, please.
- 02:05:59And we also did not have any resettlement due to non price errors for q one as well.Next slide, please.And this slide just shows the number of disputes that we've had, in q one so far, and 100% of these dispute resolutions were timely.Next slide, please.And this, table just shows the, percent change from initial to final and final to true up.
- 02:06:33You'll notice there is a little bit of a spike from the initial to final as well as the very end of the final to true up.Those were due to differences in load from the different settlement runs, so it did have a little impact on settlement, charges.And you'll notice that the table at the bottom previously used to have data from 2011 to present.The table was starting to get a little bit crammed, so we did decide to roll off the 2011 to 2015 data and just keep the last ten years' worth of data to to help with the the visual and to keep the table clean.Next slide, please.
- 02:07:20And, we also rolled off the first those first five years of data as well from these next two slides just to help, with the visual representation.So we just kept the last ten years' worth of data.So this slide is the, real time average, medium, max, and min of the total charges, and the next slide is the same data for the day ahead.Next slide, please.And this just shows the availability of the ESI ID, consumption data.
- 02:07:54So this is the load volume availability percentages.Next slide.And this is the ESI ID count availability percentage.Next slide, please.And this is the net allocation to load slide.
- 02:08:13The one thing you will notice is under the RMR settlement bucket, in March of twenty twenty five, you will start seeing from this point on, RMR settlement since, that resource did, their contract did start in March.So I just wanted to point that out.And this is the net allocation to loan by congestion management zone.And the last slide is the securitization default charge and uplift charge by month.And I did see we had a question in the queue.
- 02:08:55Yeah.Go ahead, Jim.Thanks.Thanks, Magie.Appreciate this.
- 02:09:00A couple of things.The the ESI ID consumption load available for initial settlement, you're showing it.The volume itself is is north of 85% or 80% in that range.And then the actual ESI ID is available for initial settlement is well north of 97%, as I recall.Tells me that there's kind of a issue with certain large meters, more than likely, IDR meters, maybe making it into initial settlement.
- 02:09:35Is there a way we can add that kind of analysis maybe next quarter as to what meter type is really missing.And and again, I think that's the reason for that you brought up the big spikes in the resettlement.It it it has a financial impact if we're using default profiles for certain meter types that create kind of a cash flow issue with us and having to pay out at at an initial settlement, wait for final to get that trued up.So the intent is not to change anything at ERCOT, but really to provide better information to a meter read entity so that they can hopefully get these things in on time.But is that something you could include in the next, quarter session?
- 02:10:20I can take that back to our, data aggregation and metering group and see if that's something that they could look into.But I I would have to talk to them first before I can make any promises.Totally understand.Just wanna see if you can get that ball rolling.And if if it's too much, that's fine.
- 02:10:38But I think you can understand where our concern is is, I think we we were one, and I've talked to many others that have been impacted by that large change in load, from initial to final, especially around January.So we'd appreciate anything y'all can provide to us next time so we can hopefully get these meter reads in on time.Okay.I'll look into that and, follow-up.Thanks, Jim, and and thanks, Magie, for a great report.
- 02:11:08We have a clear queue, so I think we're good to move on to, let's see, the 2024 annual UFE report, with Joe Lara.Joe, are you available?Yes, sir.I'm ready to go.
- Item 7.3 - 2024 Annual UFE Report02:11:26Hi.
- 02:11:26I'm Joe.I'm with the data loading and aggregation unit here at ERCOT, and I'm gonna present the 2024 UFE, report.So just to kinda go into, too deeply is the UFE basics.So UFE is, the calculation of generation, less load, plus losses.And some of the sources for UFE include generation measurement errors, any DC tie, and upper energy.
- 02:11:56There's various reasons for load to contribute to UFE as well as to losses like model error, loss calculation error, and so forth.If we have negative UFE, which we did in 2024, indicates that load and losses were overestimated.Next slide.And, again, this is just, graphical presentation of the same thing.So we get the gap as to UFE.
- 02:12:26We aggregate, from the load data up to an an out excuse me, an outbound losses for transmission and distribution, and then we calculate the UFE.Next slide.And by protocol, we are required to report this information each year.This was posted earlier this month.Actually, in the at the April.
- 02:12:56Next slide.And for 2024, our, total UFE was, negative, four million eighty seven sixty two megawatt hours.Cost a hundred 44,000,000.That was about negative point 875% of the total load.There's a breakdown for, UFE by IDR and IDR as well as for transmission load.
- 02:13:34Next slide.As I mentioned before, 2024, we had, negative EFE, most of the year.It was quite a bit different than past years.You can see how the dark green line, 2024 was, quite a bit different than the past years.And, that was probably due to the transmission losses, allocation.
- 02:14:03Next slide.And the UFE monthly, megawatt hours by month.The entire year, it was negative as of February.Again, this is, attributed to the, loss factor the loss calculation we've had attributed to the load.Next slide.
- 02:14:34And here is the cost by the month, to follow the same way as UFE.So it's negative, throughout the year.Highest in May and and also in August.Next slide.And here is the historical year historical data, by year for the past, twenty somewhat years.
- 02:15:02So this last year, we had negative UFE.It has happened in the past, but not to this, quantity.So 2024 was, quite a bit higher than it has been in the past as far as negative UFE and, negative cost.And there's a note just to kind of reiterate that the, UFE was it's basically just load added to the load adjusted, for losses.Next slide.
- 02:15:40And it should get better, going forward.So in April excuse me.In March of this year, we implemented NPRR1145 just to kinda remind I mean, remind everyone here, we basically started we changed from using the seasonal base case models to using the, the, loss factor from the state estimator, provided by our energy management system.And here is the current protocol for how we're given the loss factors as well as how the state estimator, calculates and provides that data for us to use.And, again, we implemented this in implemented this in March twenty eighth of this year.
- 02:16:28Next slide.This is the, a chart of the 2024, transmission losses in UFE.So as you can see there, when UFE, excuse me, the transmission loss factors, were adjusted in March of twenty twenty four, to include the base case models, there is a, but big jump from the 2% loss factors, to 3% in March and carried forward for the rest of the year.And that kind of resulted in the UFE going below zero for the rest of that year as well.Next slide.
- 02:17:16And this I wanted we wanted to also show you how, the loss factors in UFE have done since, implementation of November.So, again, we did that on March 28.Before implementation, the the UFE actually had negative value, but the absolute value before that was point 8%.And after implementation, the average UFE dropped to, absolute value of point 6%.So there was a sizable decrease in the UFE since implementation of November.
- 02:17:57Also, I should note that the loss fact the loss factors also decreased.It went from about, 3.19% before implementation to 2.4% after implementation.And you can notice that the loss factors, that come from EMS do follow load.It is no longer static.And next slide.
- 02:18:29This is just the reiterate what I just said.There it's it's we at aftermentation, we did see the, the tractors and all those factors lower than the BCS based case models and as well as the daily average fee also change from negative to positive.It's also decreased in terms of absolute values.So we are seeing what we had expected to see when we made the business case for a change in the loss factors.Next slide.
- 02:19:05Do you have any any questions?Thanks for the report, Joe.I I do do want to echo what Brian mentioned in the chat.Thanks for giving us a a sneak peek of the performance since 11:45.I think that that's really helpful.
- 02:19:23I feel like you're dodging lots of questions today.Bill Barnes isn't in the room, and he usually hits this report pretty hard.So you picked a good day.Thank you.Nothing else in the room or in the queue.
- 02:19:35Appreciate your time, and we're good to move forward to the next report, which is the annual UDG report from Dan Mantina.Dan, are you available?Yes.I am.Can you hear me, Blake?
- 02:19:51Yes, sir.Great.
- Item 7.4 - 2025 Q1 and 2024 Annual Unregistered Distributed Generation (DG02:19:55Report Updates) Hey, everyone.This is a DTG report.Excellent, please.
- 02:20:03Starting with the annual report, for 2024, the total was just over 2,800 megawatts.And this report, for the first time, we've excluded, battery storage.So this is something we've done with the quarterly reports back last year, and so we've implemented that practice in annual reports as well.Next slide, please.This slide shows just the year on year growth within the annual report.
- 02:20:39Between the annual report and the quarterly UDG report, the the NOEI data is different.So so the annual report captures all NOEI DG capacity, while the quarterly has a has a two megawatt threshold that NOEI's have to meet if they if they're required to report.And between 2024 and 2023, there's been a 10% growth in the annual numbers.Next slide, please.Moving on to your q one of twenty twenty five.
- 02:21:15This shows a summary for for the quarterly report.Here, the DG reports the DG total is 2,800, just slightly over that number.And once again, the, the DG battery storage carve out is kind of provided here at the bottom of the table.Next next one.This slide shows the quarter of a change between q four of last year and q one of this year, and there's been a 53 megawatt growth in the quarterly DG total.
- 02:21:54And next slide.This is the last slide that just shows the quarterly DG growth, including q one here.And that is all I had.Are there any questions?Thank you, Dan.
- 02:22:16No questions in the room or in the queue.Appreciate this report.Great.Thanks.Alright.
- 02:22:26Moving forward, there was an item that that caught my ear at at the last open meeting.There was a mention of RMR life cycle uplift cost that we could expect, to see on statements in May.I I asked Ino to come give a brief update on that process and some expectations going forward.Thanks for being here, Ino.Sure.
- Item 7.5 - RMR Life Cycle Uplift Costs Expected Over Next Few Months02:22:51Good morning.I'm not sure how many of you are familiar with what's going on as far as RMR and MR8, issues.But, clearly, we do have an an RMR unit right now as, actually, as Magie said before, the Braunig number three, which was approved in December 2024.And currently, ERCOT is negotiating with the life cycle and CPS to move 15 dual fuel combustion turbines from the CenterPoint area in Houston to San Antonio.The, the board of directors already approved those, whether we, we go with the RMR units one and two or with the life cycle units.
- 02:23:47Those resources are gonna be moved to nine substations in the San Antonio area.And because they're gonna be in the substation, they're gonna have to run on, diesel fuel, not natural gas.So I do I don't have a presentation.It's because as of today, we do not have an agreement final agreement with Lifecycle.And I'm talking about an ERCOT agreement between ERCOT and Lifecycle.
- 02:24:22But we're very close.We're not there yet.That's why I wasn't sure what I could and could not share with you at this point.But what I can tell you is that because of this work that is being done, both CPS as well as Life Cycle are currently incurring a lot of costs.In fact, they've been working on this for several months.
- 02:24:50As you can imagine, putting combustion turbines in a substation is not an easy task.There's a lot of studies that have to be done, preparation of the substations, roads, and so on and so forth.Back on February 25, Erica presented at the board of directors the an estimated cost of approximately $54,000,000 for both, the entire cost of the life cycle units.And that included approximately 9,000,000, $29,000,000 for life cycle and around $23,000,000 for CPS costs.As of today, that's about still about the same cost.
- 02:25:40Could change tomorrow, but that's more or less in in the ballpark.And I'm I'm bringing this up because, clearly, those two entities, especially CPS, are incurring costs, and there's no way for them to recover, payments right now, recover costs.Because as of today, we don't have a QSE.We don't have a contract.Hopefully, we're hoping we're crossing our fingers that by the end of the week, we'll have a contract, and then we can start making payments.
- 02:26:16So what is that gonna entail?Those resources are still in Houston.In order to bring into San Antonio, First of all, CPS has to complete their work, give the green light to life cycle to move those resources.We have to they have to test them, and we must raise through those resources.Now we may be able to raise through those resources before they move to San Antonio.
- 02:26:46But in order to make a payment in the system, we have to have those in resources in the model so we can settle like an RMR, individual resources, individual units.But that's not gonna occur for a while.Maybe towards the June all the way through August, potentially.It's not yet clear, a %.In the meantime, we do have to make payments.
- 02:27:17So as soon as we have a contract and as soon as we have a QSE, which is gonna be CPS, by the way, then we'll start calculating payments.The way we're gonna do that is gonna be through a miscellaneous invoice.And for those of you that are new to this market and may not understand what that means, it's basically on a spreadsheet.We're gonna calculate weekly payments to the QSE, and then they can distribute the money.As soon as those resources are registered, we can remove those resources from the manual calculation and settle them in the system.
- 02:27:58And the reason the reason I say that is because most likely, it is possible we may not have all these resources registered at the same time.So for example, in May, whatever is remaining of May, if we settle them, if we settle the life cycle cost and CPS cost manually, but then in June, let's say five units get registered or six units or whatever number, then we'll switch those to, a system settlement, and we'll continue with the manual settlement until all resources have been registered in the system and in the system.That could take a month, two months.We're not a % sure at this point.So it is possible the QSEs will see QSEs that represent load will see two costs, two payments.
- 02:28:48One manually through a miscellaneous invoice, which is basically a calculation in the spreadsheet, and then Treshit will send an invoice to the QSE.At the same time, maybe a system payment as well.But we're gonna separate the cost, obviously.We're not gonna charge them twice.That's the objective right now.
- 02:29:11And I'm not sure if you guys are familiar with the the Brownie three resource, but, if you have seen the contract, but it part of the con it's published, but it's in the MIS.But part of the contract includes a table in an appendix that shows the budget amount for the remaining two years.We are gonna do the same thing with the life cycle units.We're gonna have a table that shows you the dollar amount for every month plus the standby for every month.The only difference is that when we calculate the standby for RMR units per protocols, we take the entire amount dollar cost, if you will, total cost for a two year period and divide it by the number of hours in that period.
- 02:30:03For the life cycle units, we're not gonna do that.We're gonna calculate the standby price by taking the budget for the month, dividing by the hours in that month.The reason we're doing that is to get as close as possible to actual costs.Eventually, they're gonna have to CPS and life cycle will have to submit actual costs just like an RMR unit.What we wanna pay on the initial is close as possible to actuals, and that's the intent.
- 02:30:36Unfortunately, I can't share with you exactly what those numbers are gonna be at this point.But if you look at the presentation that we did at the board of directors, approximately $36,000,000 were supposed to be incurred in the first year and $18,000,000 in the second year.First year, meaning we signed the contract in March, '12 more twelve months and then second year is the remaining.That is still the case more or less.But I do wanna add that out of those $36,000,000, a significant portion of that will be allocated most likely to the first three months once we send the contract.
- 02:31:25So I wanna set the expectations.Because CPS and life cycle have been incurring costs for the several months now, and they keep accumulating.And we need to make payments so we can continue with this project.I believe that's all I wanted to cover, but I'll welcome any questions.Thanks, Ino.
- 02:31:48First up, Brian Sams.Hi, Ino.Thank you.Appreciate you being here and giving us this update.I just I assume this is gonna be part of y'all's process to have, market notice flagging those miscellaneous invoices when those come out.
- 02:32:05Yeah.I'm glad you asked that question.So I always forget what to say unless I have a PowerPoint.Yes.Every time we have a miscellaneous invoice, weekly miscellaneous invoice, we're gonna follow-up with a market notice that would indicate the total amount that we are paying within that week and this, total as well as the standby price.
- 02:32:29So QSEs can calculate their share of the cost.However, POCs can also check with their account managers if they have any questions so we can help them, figure out what the actual particular cost, for the that week period might be.Great.That's that's also helpful because, you know, customers will have questions too when they when they see a miscellaneous charge shows up.You can point back to that.
- 02:32:57So appreciate that.Understood.Yes.Thank you.Anybody else?
- 02:33:03Tim Marino.Jahurst is me.Blake Hall with LCRA.I know I'm preaching to the choir here, but miscellaneous invoices are, administratively burdensome burdensome to process on our side in terms of, allocation and things like that.Just want to encourage, as expeditiously as possible to to move those into the system.
- 02:33:25I I realize y'all are at the mercy of, you know, when these things can be cited, and so I just wanted to communicate that to y'all.We appreciate your that comment, Blake.We are doing the best we can given the circumstances.As I said before, the only way to settle this in the system is to have those units in the model.I'm not concerned about the QSE units, having a QSE.
- 02:33:51We have to have a QSE, but having them in the model because registration, requires data, specific data by resource.And that's where we are right now, trying to collect that data and get it through the systems, through the model so we can, raise them.And, by the way, I think everybody knows this.When you connect a new generation to the grid, you gotta do studies.Right?
- 02:34:18You have to make sure you're not gonna burn the wires.So there's a lot of there's a lot of background work that has been done, but both by CPS as well as ERCOT to make sure those units can be safely connected to the distribution system at CPS.Thanks.We we appreciate this is a unique situation, so completely understand that.Next up, Jim Galvin.
- 02:34:42Yeah.Thanks.You know, I assume that the miscellaneous invoice or at least the supporting information will will still be along the charge components that are in the RMR, sections of the protocols.Is that correct?You'll provide a standby and all of that, you know, the or are we looking at just an itemized cost?
- 02:35:06I'm I'm trying to see how we align the specific cost to a a given data determinant at some point, and questioning if that standby cost, for instance, may change over the life cycle of these contracts as you finalize the agreements.Yes, Tim.Thank you.I'm glad you brought that up.Yes.
- 02:35:29Our goal is to make it, as as close as possible to the RMR settlements, and if we need to, add the the bill determined for the standby price.The only difference, though, remember, is that I'm not sure we can do it because the standby price is unit specific.Right?The the standby is unit specific.Initially, we're just basically allocating, let's say, x amount of dollars in the month to, to a to basically a QSE, part of their low ratio share.
- 02:36:01So I'm not sure we can, have a a resource specific bill determinant, but definitely we'll look into it.Yeah.I I think the only concern I have is this is unprecedented.And how do we, as a loads who are paying for this, know that these costs are are vetted appropriately and assigned in the right places?But we'll dial into that and see if we can get more.
- 02:36:24I do appreciate the the difficulty of how you guys are having to handle this and, definitely appreciate your heads up today for this.Thank you.Sure.We'll do our best, Jim.Thank you for the comment.
- 02:36:38Thanks for those points, Jim.Next up, Kevin Hansen.Yeah.Kevin Hansen of.You know, I'm curious.
- 02:36:45Is there any interest accumulation on top of these costs?Are there any accrued these?I'm sorry.Can you is there any interest payments on top of these?No.
- 02:36:56Okay.So it's just the raw cost itself with no interest on top of that.Right.No.Okay.
- 02:37:00I'd well, I can't disclose what's gonna be in the in the in the agreement, but as there's no we don't pay interest, on any of these costs.Okay.Alrighty.No.That's a clear queue.
- 02:37:16Appreciate your time today.Thank you very much.And, please, if you have any questions, let me know.I'd be happy to answer them.Alright.
- 02:37:25This is a momentous moment.
- Item 8 - WMS Revision Requests (Vote)02:37:27We're finally moving to the next item in the agenda.
- Item 8.1 - Related to NPRR1264: COPMGRR051, SMOGRR031, and VCMRR04302:37:31Number eight, which is going to start with impact analysis.The first three items here are all related to NPRR1264.I believe we're waiting on PRS recommendation of this NPRR and for development of the IA.
- 02:37:49It's my understanding these can just remain tabled, and we don't need any action at this time.So we can move forward to language review.
- Item 8.2 - VCMRR044, RTC+B – Mitigated Offer Cap for Hydro Generation Resources02:37:59And the first item up is VCMRR044, which has to do with MOCs for hydro generation resources.Magie, are you going to be introducing this one to us today?Sure.
- 02:38:13I can.So, this VCMRR was written because of a key principle that was approved during RTC a few years back.So that key principle mentioned that hydro generation resources that are not operating in synchronous condenser mode should have their energy offer caps equal to the mitigated offer cap.So while going through the language and trying to work out the implementation, because hydro generation resources that are operating in synchronous condenser mode are actually not dispatched by SCED, the simplest solution was to just set the mitigated offer cap for all hydro generation resources equal to the real time system wide offer cap.And, these discussions did take place at the current RTC+B meetings.
- 02:39:04I believe it was sometime last year.So the task force has seen this language.We are just finally submitting it.So this is what this VCMRR just lays out is setting that mitigated offer cap equal to the, real time swap cap.Thank you, Magie.
- 02:39:28And I do remember discussing this back at the task force, and spending some time on it.LCRA is is comfortable with this.I'm kinda waiting for to see if anyone in the room or on the phone wants to hop in the queue, but I do think this would be a a good item for the combo ballot and wanted to check the pulse from the group on that.Getting a few thumbs up.Alright.
- 02:39:54Thanks for bringing that to us, Magie.The next item up is SMOGRR032, which has to do with EPS metering facility forms.Is there anyone here from?Sorry.Okay.
- 02:40:13We have Britney here.
- Item 8.3 - SMOGRR032 and SMOGRR03302:40:15Thanks, Blake.Yeah.SMOGRR032 and SMOGRR033 are both forklifts.Other binding documents into the settlement metering operating guide.
- 02:40:25You've seen a few of these already.There are no substantive changes.They are all, basically administrative.We create a new OBD and we change a few references in some related sections.And then, also, meter working group has seen both of these.
- 02:40:43Perfect.Thank you for that.I I think these are also good combo ballot candidates.Any concerns with that from the group?Perfect.
- 02:40:57Thank you for that, Britney.
- Item 11 - Revision Requests Tabled at PRS and Referred to WMS (Vote)02:40:59Moving on to agenda item nine, the revision request tabled at PRS and referred to WMS.
- Item 11.1 - NPRR1070, Planning Criteria for GTC Exit Solutions02:41:05NPRR1070, planning criteria for GTC exit solutions.I believe this one is still pending comments from EDF.I don't expect any discussion here today.
- Item 10.1 - NPRR1275, Expansion of Qualifying Pipeline Definition for Firm Fuel Supply Service in Phase 302:41:18And the next item is NPRR1275, expansion of, qualifying pipeline definition for firm fuel supply service.ERCOT filed comments on this after the April 24 open meeting stating that they would like to keep this one tabled.We received comments from the commission at that open meeting that seemed to indicate that they might want to open a rulemaking to inform any issues regarding program expansion.Rewind from that at at the PRS just prior, it appeared WMS received a request to produce a list of issues that could help inform commission staff on expansion.I'm now recommending that we actually don't pursue that agenda item and let the rulemaking process inform the commission on on these issues.
- 02:42:11But I did wanna open it up to the group and see if there are any comments or if ERCOT wants to, expand on their written comments.Ryan, I I see you in the queue.Do you have a comment here on twelve seventy five?Nope.My question was just, I might have missed it, but I wanted to did agenda item nine get covered in the western?
- 02:42:40Maybe I've got an old agenda here.That was a late addition that I didn't have on my personal notes.We we will go back to that.And I guess if no one has any I had I'm sorry.Go ahead.
- 02:42:59So I'm just looking at the commission's PUC rulemaking calendar for, discussion at the May 8 open meeting and review of this.I don't see firm fuel anywhere on here.So, it would be good to have that clarified if the commission has a rulemaking or has a plan to take this up as a rulemaking.Is anyone present from actually, there's Matt Arth in the queue.Matt, would you please go ahead?
- 02:43:36Sure.This is Matt Arth from ERCOT.I don't wanna speak for the commission, but, just to excuse me.I'm a little bit under the weather, so my voice is kinda rocky.But we would continue to support the comments that we posted, which were the twelve seventy five.
- 02:43:54We would ask for main tabled, pending further commission action.And, it is my understanding that the commission does intend to open rulemaking, but, I I didn't I wasn't under the impression that they were going to, do that at this tomorrow's open meeting.So it might just be, I think, a matter of them balancing the, their resource constraints in terms of when they open that rulemaking.But, but that was my understanding that one was forthcoming.Thanks for that, Matt.
- 02:44:33I I'm not opposed to tabling this.I think there's some healthy discussion that needs to happen around what, qualifying pipeline can be, I look forward to when that happens, but I just wanna make sure that we're not pointing to the commission for rulemaking that we're waiting on.It's not even on their their, you know, proposed process.So, that that's that's what my concern is.And if if, we need to have it as an agenda item here for another time, that also fits within the box if we can table and talk about it another time.
- 02:45:08I don't I I think the goal would be to have revisions in place for the, 2627, procurement period.So plenty of time to get there, but, it'd be good to have some, you know, visibility in the plan.So thank you.And I can commit to bringing those points up at at TAC in my report and just make sure I'm clear on on what's needed out of WMS to handle that discussion.Britney, please go ahead.
- 02:45:40K.Just procedurally, excuse me, 1275, sorry, was referred to WMS, so we would need to be responsive even if it is just to request continuing tabling in comments.And then, when y'all go back to December, previously PRS tabled there without a referral and then just recently referred to WMS, so you would need to be responsive.Thanks.Thank you.
- 02:46:08So with twelve seventy five now, we need to take action in tabling it.Is that a combo ballot, action from the group?Everyone seems to support that, so let's go ahead and put that on the combo ballot for tabling.Any working group or just request table?I'd recommend pausing because my conversation at TAC, I I kinda asked or previewed what I thought the direction should be and didn't get any further instruction on, you know, seeking to highlight issues at WMS.
- 02:46:43So I'd like to clarify that.Thanks, Britney.
- Item 9 - NPRR1255, Introduction of Mitigation of ESRs (Possible Vote)02:46:56And back to agenda item number nine, which is twelve fifty five.Ryan, would you like to lay out this item, or are we expecting comments from from Caitlin?I see Caitlin in the queue.
- 02:47:13So, Caitlin, would you like to preview twelve fifty five for us?Sure.But I'm I'm happy to defer to Erkad and Ryan if if you'd like to go first.Sure.I I I would say that, ERCOT probably doesn't have a lot to say with respect to this NPRR, but maybe just to reiterate a few points.
- 02:47:39This this concept was discussed at the CMWG beginning in September of twenty twenty three.So over a number of months, we kind of review different concepts, refine them, and the the NPRR1255 is really a reflection of that, process.We deliberately wanted to make sure that we set a fairly high threshold, a light touch in terms of the mitigation framework, considering some of the unique challenges that, energy storage resources face.So what we have done here is essentially, looking at, instances where an energy storage resource has been flagged as having market power and has a very high helping shift factor, 20% or more.Then, in that case, the the mitigated offer cap would be a function of the maximum shadow price of a given constraint, and the shift factor less a penny.
- 02:48:39That, sort of by definition is the highest possible price that would be allowed that would also allow the, congestion to be relieved, on the on the constraint.We did do a back cast as part of the analysis, of this NPRR.And, looking at, I think it was 2023, this would have impacted less than 1% of ours.I think it was point 34%.One of the comments that we subsequently filed on this NPRR was to add, basically, something that would increase the threshold further, and that's the concept of this, available stored energy calculation.
- 02:49:21And, essentially, we we convert that into an hourly value.And, when the available stored energy is less than 25% and I don't know if it's is it showing up on there?Yeah.Okay.Yeah.
- 02:49:41Then, the resource would not be subject to the this mitigation framework.Instead, they'd just be mitigated at the system wide offer cap.So we we thought that that was, something that had been suggested from stakeholders, and we thought that, while it it does, to some extent, increase the threshold further, in in instances where there's basically less than fifteen minutes left of of energy, it it seemed a reasonable compromise to account for state of charge and to reflect the fact that there may be limited operational value for such a low state of charge.So, I think that's all I kinda wanted to know here.Oh, yeah.
- 02:50:22So here's kind of the calculation.You know, I I think at the at PRS, I I did a brief example that if you had a a hundred megawatt, hundred megawatt hour battery with a minimum SOC of zero and a current SOC of 24 megawatt hours, then if you ran the math through that equation, that would give you a number of 24%.And so that would be deemed lower than that threshold, and so mitigation would be, go back to the system wide off cap.I think that's all the, points I I wanted to raise here.So I'm happy to pass things on or answer any questions.
- 02:51:05Caitlin, do you wanna highlight anything else or or seek direction on or what what's your desire here for 12:55?Can can you hear me okay in the room, Blake?Yes, ma'am.I would like to seek direction.I I do wanna say thank you to to ERCOT.
- 02:51:28I I sound actually Ryan's last comments, are very helpful.They've been working with us off offline.They they've been really helpful, and this is a challenge.You know, I I think we are thinking about this, like, because ESRs are in a a unique position where they're always online, really, the only way you can manage your state of charge for, you know, an ancillary service obligation or any other obligation you'd have under, you know, a bilateral contract or something for for a day ahead commitment is through your state of charge that we use our our offers to manage that.And so I won't say that the word that ends in in UC, but I think we would consider this sort of a administrative action where we would be dispatched earlier than we would think we would, and then we would no longer have the state of charge.
- 02:52:22We'd have to charge back up.So we're trying to solve this problem about being made whole.I don't think we are seeking a make whole, but we just want to make sure that that 25% filter Ryan described at the end of his comments, is the correct filter.You know, I I think if it could be coded as a variable so that we could start higher and go lower or vice versa, I think, we'd like that.And I think the point I was gonna make was that we really hadn't sketched that that filter in the stakeholder process.
- 02:52:56As Ryan pointed out, we have discussed the concept at at GMWG of the NPRR.We never discussed the actual language.We never discussed the 20% filter.I I'd also point out the 20% filter is applied through the formula you have on the screen, which is the available stored energy over the next hour.We we have two hour batteries.
- 02:53:19A lot of people have two hour batteries, so this doesn't take into account duration really.So we wanna think about that.And then, you know, I see Bob in the queue, but something he raised at PRF is how this mitigation would work in conjunction with the SSC requirements we are considering in in RTC.You know, I I think in some situations, it might end up stricter or worse than it is now.So I I understand ERCOT wants to not delay this.
- 02:53:51I don't think I'm asking to delay it, but I'd like to refer this table and refer to CMWG to consider those two things, the 25% filter, and then walking through, an analysis of of how this would not an analysis, but walking through an example of how this would work, in conjunction with the requirements proposed for RTC.Thanks, Caitlin.Bob, do you have a comment?Yeah.Just real quickly.
- 02:54:21And, my my issue is a little different, and it's not just really associated with with this NPRR.It's kind of a little bit of a bigger picture of if you look at the way I asked that question, is that, there's a lot of risk, but the way we've designed, the RTC plus b when it comes to RUC, short, charges.And what, you know, my issue here is and and, Ryan, this is a great job.I think this is probably the best we could get on mitigation.The only thing I'm wondering about is is there a way or it may not be in this NPRR or another way to look at that on if we are mitigated and we go below our charge, especially with the longer duration SOCs that our cost is asking for for ancillary services, that somehow we mitigate those charges or something.
- 02:55:19So that's really what I was looking at.We've got risk already with the way it's designed today, and this adds a little more risk to it, albeit probably very small, but it is there.And that that was really more of an acknowledgment and figuring out that we may need to do something there on a bigger picture.Comment from Ryan.So, to I guess, to Bob's question on the RUC capacity short, I I think that that might be a better discussion happening at the RTC task force just because that seems to be specifically about, you know, how our how our, ESR is considered in the RUC optimization under RTC.
- 02:56:13So that that might be my suggestion in terms of where we we deal with that question.Now, I I think when it comes to the to this NPRR, we're we're more than happy to to talk through questions.I think one of the things that I noted at PRS, and I'll just raise it again, is that sort of by definition, adding this 25% filter takes a very small number, point 34%, and and almost by definition, reduces that further.And so I think our position that I think we've stated is that we would probably we've tried to incorporate every piece of feedback that has been suggested by stakeholders in this.We know this is mitigation, which is never, a lot of fun to do.
- 02:57:08But we'd be concerned if we change that further.If we increase that threshold further, we're now moving from a framework that is more theoretical than possible.It would be hard to even imagine many circumstances where these specific sets of scenarios would actually apply.And if you fast forward to RTC when congestion is going to be, there's more opportunity to manage congestion with the advent of real time co optimization.We're we're just not seeing necessarily where the where the the questions need to be answered or what further kind of analysis needs to be done.
- 02:57:47If it's a question of an example, like I said, we we can kinda go through that, but I'll kinda just leave that, as as ERCOT's, position on this.Yeah.Can I respond to Ryan?This is Bob.Yes, sir.
- 02:58:04Yeah.Yeah.Ryan, like I was saying, I I think this is going down the right path.We've gotta do mitigation.I wasn't really having a big ask for you out of this NPRR on that.
- 02:58:16I wanted to just bring that up, and I do agree with you that in the RTC plus b, is right place to really go after that.I just wanted to put that out there that that is a little bit of a concern.That was it.Thanks, guys.It seems like the desired direction is to refer this to CMWG.
- 02:58:41That seems like a good combo ballot item.Any concerns with that from the group?Sounds like a good path.Britney, you have what you need on there?Okay.
- 02:58:58CNWJ is your group?Yes, ma'am.Alright.Moving forward to, some working group reports.
- Item 12 - Meter Working Group (MWG)02:59:08Item number 12 is the meter working group.
- 02:59:10I don't think there was a presentation posted.I do wanna see if Kyle's available.If not, I I think I can give an update.I don't think Kyle's on the line.
- Item 12.1 - NPRR1263, Remove Accuracy Testing Requirements for CCVTs (MWG02:59:24(Possible Vote)) I I think they needed an an additional month to discuss NPRR1263.
- 02:59:30So we'll have, an update on that one hopefully next meeting.The next working group report is supply analysis working group.
- Item 13 - Supply Analysis Working Group (SAWG)02:59:39Kevin, are you available to give the report?Yes.I am.
- 02:59:44Next slide, please.So the two items we did discussed at this month was the, long term load forecast, which I think was the third round, the third version delivered during that month.Also, we discussed the coal to gas inclusion in the CDR report.So regarding the long term load forecast, it was presentation jointly by Kate Lamb and Sam Morris, give a quick overview of their, new process they're using.Couple items that were brought up and discussed was, the contracted loads were not necessarily in the study process.
- 03:00:28The current data centers only curtailed during extreme price events, and load reduction is only about 10% of peak load.Either this fall or in this early winter, a consultant's being hired by ERCOT to prepare a low a global to local look of worldwide chip use and installations that would impact the ERCOT region specifically.From the historical data, only, 26% of the total offshore loads actually showed up is what they found.ERCOT also mentioned they're preparing and publishing hourly load forecast out to 2044.Additionally, they're also preparing hourly load forecast based on each weather year from 1980 to 2023.
- 03:01:11And last thing that my notes were is that, Arcad plans to update their load forecast in either February or March of twenty twenty six.Next slide, please.Regarding the coal gas conversion in the CER, Pete Warren can give a presentation, within it, ERCOT outlined a proposed strategy to incorporate before and after line items to, capture planned fuel conversions.They're not eligible to be included in the CRS planned resources.Current project examples were included Spruce 2 and Clutter Creek.
- 03:01:49After the SOG meeting, ERCOT signed a re modified proposal to SOG, server, and report and reporting examples entailed creating a new unit status code called OPERDashUNFC, unconfirmed plan fuel conversion for an operating unit.Mark, I mentioned that, these changes will not require a new NPRR, but a future NPRR will provide transparency of this change.And that was it that that saw this month.Thanks, Kevin.Any any questions from for Kevin?
- 03:02:29Alright.Appreciate the report.Takes us to number 14, which is our combo ballot vote.Looking for a motion and a second to approve.We got a first from mister Shane Thomas and a second from Andy Winn.
- 03:02:56Alright.
- Item 14 - Combo Ballot (Vote)03:02:56If y'all are ready to vote.Thank y'all.You have your, seven items there.Everyone has reviewed them.
- 03:03:06We'll begin with the sorry.It's not rolling.Oh, just a second, please.Sorry.I'm having a technical issue.
- 03:03:52If you can just hold.Thank you.Alright.We'll begin with the consumer segment.Rick?
- 03:04:17Yes.Thanks.Alvaraj for Eric.Thank you.Preeti?
- 03:04:26Yes.Thanks.And Mark?Yes.Thank y'all.
- 03:04:32Cooperative segment, Blake?Yes.Lucas?Yes.Jim?
- 03:04:40Yes.Thank you, Britney.And Matt for Joden?Yes.Thank y'all.
- 03:04:47Independent generator segment, Theresa?I see you in the chat.Thank you, Teresa.Roy, thank you for the screen reminder.Brian?
- 03:05:01Yes.Thank you.Andy?Yes.And Tom, who I don't believe is on the call.
- 03:05:10Tom Burke?Alright.Thank you.Moving to independent power marketers, Amanda?Yes.
- 03:05:20Thank you.Ian?Yes.Thank you.Shane?
- 03:05:24Yes, ma'am.Thank you.And Robert?Yes.Thank you.
- 03:05:28Thank you.Independent retail electric providers, raise pay for Bill?Yes, ma'am.Joshua?Thanks, Josh.
- 03:05:40See you in the chat.Austin?Yes.And Ruseby?Yes.
- 03:05:48Thank y'all.Investor and utilities, Jim?Yes.Thanks, Britney.Ivan?
- 03:05:55Yes.Thank you.David?Yes.And Rob?
- 03:05:59Yes.Thank you.And finally, municipal segment, Curtis?Yes.Mike?
- 03:06:07Yes.Thank you.Ken?Yes.And Faye.
- 03:06:16Faye, are you still with us on the line?Oh, yes.Thank you.Thank you.Motion carries unanimously.
- 03:06:32Thank y'all.Appreciate that, Britney.Few more items left on the agenda.Back to some working group updates.Next up will be, with the congestion management working group update.
- 03:06:52Are you available?Yes.I'm here.Alright.Go ahead when ready.
- Item 15 - Congestion Management Working Group (CMWG)03:07:05Okay.We move to the next page.Okay.So at the last month, so the staff, provide the updates on the CRR auctions.So, we still see the peak workday case in last month took, long hours to solve, which is a significant higher compared to the, last time we have, the sequence.
- 03:07:39So that's therefore, the 2025, the second six, you know, annual auction sequence one will become the first, you know, the new transaction limits.Again, these limits will not be a permanent limit as we mentioned before.So still look at the revision request regarding, removing the multiple months bidding functionalities and the options of the price report.They're also considered to, you know, include a change to increase the minimum base quality from the point one megawatts to one megawatts.So we'll continue discussion those items in the future CMWG course.
- 03:08:24Let's go to the second one.So ERCOT presented some information related to the, record in high prices on, 02/19/2025.So stakeholders bouncing back multiple great ideas to ensure, like, similar events, doesn't were not, you know, result in similar price outcomes.ERCOT was considered if the IMM should, apply on the situation.So it's clear that, we will have more conversations on this topic.
- 03:09:05And, you know, any changes, you know, we may need more analysis and before we're making the changes.And now we can move to the best that can be the next one.So I'll call provided some updates highlighting the point to point obligation bids and, the point to point to point with links to an option in divorce records.So this issue has been introduced in 2021, but since the, winter storm impacts.So this had been, you know, left behind.
- 03:09:47And, mentioned that, you know, the similar situation may resurge, if we don't take any actions.So is, reevaluating the correlations of the onboarded PTPs versus the, execution time and analyzing the submission activities to make informed suggestions regarding a fee structure.So let's move to the next one.Okay.Vistar, also presents some granular, you know, conjunction review of rights for the time of use product.
- 03:10:32So they walk through their new proposal and recommend the the deployment of a of a more granular, you know, injection revenue rights, blocks to align with the latest market changes and improve the auction speed and efficiency.So in their presentation, they mentioned that if we can have, consider more targeted products dividing the, solar and the non solar hours, we'll be able to hatch more efficiently with the obligation just require less computation resources for the CRR auctions clearing and also speed up the process and efficiency.And they're saying, you know, they can, look into, more intermittent renewables.They just say they can consider more targeted products, and we'll provide those updates in our future CMWGs if if needed.But, again, any of those kind of changes, we have to go through the regular, you know, portable changing process if, you know, go through different, working groups before we really consider this.
- 03:11:51So they are aware of that.Any questions so far before I move to the the next one?No questions in the room.Awesome.Thank you.
- 03:12:09I think a thats of, you know, from our last CMWG meeting.Alrighty.Thank you for the report.Sure.
- Item 16 - Wholesale Market Working Group (WMWG)03:12:19Next up is a report from the wholesale market working group, and Amanda Frazier is making her way to the podium.
- 03:12:29Thank you.And I can hear your bellies rumbling, so I'll be quick.We didn't have any NPRRs on our agenda this month, but we did cover three major topics, the first being RUC.And so ERCOT came with a presentation that described how their RUC process works and why sometimes you're seeing, inconsistent or confusing reasons being given for the RUC, and it it is because it's often more than one reason, that's creating the need for a rock.So they described that with the presentation.
- 03:13:09I encourage you to take a look at it.Constellation also presented a a presentation, regarding a proposed NPRR.And, actually, Andy, have you filed that NPRR?We're in the process of filing.Okay.
- 03:13:25Thanks.So a proposal that Constellation has developed related to the opt out timing for Ruck, and, they were so the presentation, described that because of the two hour notice, requirement that's currently in the protocols, there were a number of RUC instructions that were being given where the resource had no opportunity to to exercise their opt out.And so they're going to prepare an NPRR that will be filed, and we'll probably discuss that, in the future when it's when it's out.Next slide.The second, discussion was on MDR POC.
- 03:14:18I've been told we don't call this murder park, but the the maximum daily, resource outage I thought we pronounced all acronyms in ERCOT, but not this one.ERCOT gave a presentation, regarding a proposal that they have been working on internally, related to ways that they could, helped helped to create more headroom for outages plant outages.And they will be filing that as a notice, a market notice sometime in the future, possibly by the end of this month, was what Fred mentioned in the meeting.That's not part of the protocol or other binding document.So that's completely within ERCOT's timing and discretion, but they do have to file a market notice if they're proposing a change that stakeholders will discuss.
- 03:15:17So should that come out or when that comes out, we'll we'll have some stakeholder opportunity to have stakeholder feedback on that.But it was in response to discussions that had been ongoing with some other stakeholders, particularly Bill Barnes gave a presentation on behalf of TCPA and mentioned that, ERCOT's proposal addresses a lot of the, concerns that he has with the current proposal, so it's headed in the right direction.He also presented a series of additional proposals that TCPA would like to see move forward, that would allow for, more certainty about planning outages and, more flexibility for for resources to schedule those.Some of the changes that, TCPA is proposing would require, protocols, and so they committed to continuing those discussions.And should protocol changes be needed, they will file those NPRRs.
- 03:16:29And then the last item that we discussed, Magie Shanks with ERCOT came and gave a presentation on some changes that they've made, to their emergency settlements.These were not protocol changes.These were just really a clarification of the way that ERCOT is interpreting the current protocols.And the I think I'm accurately giving a short, description by saying that ERCOT had been previously, looking at all generators for eligibility for resettlement and, recognize now that doing that would created a situation where they were sometimes, creating resources or acknowledging resources as eligible for, and it's not for resettlement.It's for emergency payments that were actually indifferent to the price.
- 03:17:26And so they are now interpreting the protocols where if the, activity that created the need for the emergency settlement would not have, created a base point difference for that resource, then it will no longer be eligible for emergency resettlement.They believe that's the correct interpretation of the current protocols, and some market I think market participants agreed with that, but some stakeholders did encourage them to clarify that in the protocols.And that was, all of our discussion at WMS.Any questions?Thanks very much.
- 03:18:10Thanks, Amanda.Alright.
- Item 17 - Other Business03:18:16On to other business for this group.
- Item 17.1 - 2026 Block Calendar03:18:20The first item up is the 2026 block calendar.This has currently been on a roadshow.
- 03:18:27I'm curious if ERCOT has any comments here or anyone on the hook to present?Blake, this is Suzy Clifton with ERCOT.Are you looking for us to just kinda review the process for that schedule or Yeah.I do.Comments?
- 03:18:43That would be helpful.I I assumed y'all were just going to present it and talk through some changes.But Yeah.Basically, if Britney wants to pull that up, she can.But, basically, we've kind of created this block calendar.
- 03:18:55We do this every year, and it is not required to vote.It's just kinda giving, what we anticipate it to be.TAC has approved their schedule, and then, we'll be looking at Ross.And, you know, as long as there is agreement here within WMS that those dates look okay, obviously, if some things occur that need to be changed, we'll make modifications later in the year.But just looking at this as this is what we're telling everybody for the future of WMS for next year, this is what you're in agreement with or if there's any dates that you need to change.
- 03:19:32And if so, if we agree on that here today, then we'll be looking at getting that posted within the next month.Thank you.That that's helpful for me.I'm curious if anyone in the group has had a chance to look at this, or has any concerns with the dates proposed.And so if if there is someone that comes up after this meeting and has concerns, Suzy, what what's sort of the timeline that y'all need that, feedback by?
- 03:20:08You know, if there's agreement now, we'll just go ahead and get it posted.But if there's any concerns, then just let us know.I would say, like, within the next week, we'll start be posting that.But it's basically built on the same schedule we've always done in the past for WMS.It's the first Wednesday of the month, unless there's, like, holidays that impact that.
- 03:20:27And both the board and TAC kept the same schedule of meetings that they had last year, so it it's pretty consistent with that.I think there's some movement for, like I said, GCPA dates and, holidays.I'll I'll go ahead and roll the dice and say that we're okay with it.Perfect.Thank you, Blake.
- 03:20:45Alright.
- Item 17.2 - Review Open Action Items03:20:47Next item up is to review the open action items.I did wanna highlight that I communicated the tack that this group felt like we were complete with reviewing the eleven ninety NPRR1190 related action item.They agreed with us as well.So I'm assuming this one can be struck going forward, and we'll probably see an update there next month on the agenda.
- 03:21:14Any other comments on the open action items from the group today?Mister Thomas.Yeah.Shane Thomas, with Shell, and, CMWD vice chair.So we've got the one item on here that is for the methodology or the the timing the CRR calendar to be reviewed by, this group and where that's still necessary.
- 03:21:49At at this point, I think we we were thinking that it was still going to be, worth bringing that around just for a thumbs up even though they've got it pretty well ironed out right now.It doesn't seem owner stuff of an activity to just eliminate it just in case there are any concerns that, were missed.So Gotcha.And so that was a WMS action item sent to CMWG.Y'all feel pretty comfortable with, leaving the review still on the books.
- 03:22:21Are there any concerns from the group of of striking this one or saying it's complete?Alright.I'm not seeing anything.So, I think it makes sense to to take it off y'all's list, and appreciate y'all having that conversation.Yeah.
- 03:22:41No problem.Sorry.We forgot to put that on our update.Oh, that's why we have a list.We all we all need reminders.
- 03:22:47Right?
- Item 18 - Adjourn03:22:50Alright.That brings us to the end of the agenda.Is there anything anyone else would like to bring up before we adjourn?Alright.
- 03:22:59Seeing nothing.Y'all have a good rest of your day.
WMS 20250507 Ballot Combined
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WMS 20250507 Ballot ADER Phase 3 Governing Document
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02. WMS Agenda 20250507
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03. Draft Meeting Minutes WMS 20250402
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05. WMS-Strategic-Objectives
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06. 2024_UFE_Analysis_Report
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07. 2024 Annual and 2025-Q1 Unregistered Distributed Generation (DG) Report - WMS Update
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07. WMS_Settlement Stability Report_Q1_2025
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07. Aggregate Distributed Energy Resource Pilot Project - Phase 3 DRAFT Governing Document 02272025
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07. Leap Presentation for May 7 WMS Meeting
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07. Presentation on Non-LSE ADER Participation_VOLTUS
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07. Redlines to Draft Phase 3 Governing Document (Option 2b)_VOLTUS
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07. Notification to Non-Submitting LSE Form (Option 2b)_VOLTUS
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07. Aggregate-Distributed-Energy-Resource-Pilot-Project-Phase-3-DRAFT-Governing-Document-02272025_VISTRA ERock
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07. Vistra Enchanted Rock Presentation for May 7 WMS
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07. ADER revisions Tesla
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Meeting Materials WMS 20250507
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07. NEP Comments to WMS_May 6_2025_Support Removing the Matching QSE Requirement for the ADER Pilot Program
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07. TAEBA Comments of Support for Maintaining Third Party Participation in ADER Pilot
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13. 250507 SAWG presentation to WMS v1
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15. CMWG-update-WMS-Apri-2025.1.1
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16. wmwg-update-to-wms-of-may-05-meeting
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Revision Requests WMS 20250507
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