WEBVTT 00:00:08.480 --> 00:00:09.313 Good morning. 00:00:09.313 --> 00:00:11.090 This meeting of The Public Utility Commission of Texas 00:00:11.090 --> 00:00:11.923 will come to order 00:00:11.923 --> 00:00:13.300 to consider matters that have been duly posted 00:00:13.300 --> 00:00:17.080 with the Secretary of State of Texas for December 2nd, 2021. 00:00:17.080 --> 00:00:18.450 For the record, my name is Peter Lake, 00:00:18.450 --> 00:00:19.660 and with me today, are Will McAdams, 00:00:19.660 --> 00:00:21.293 Lori Cobos and Jimmy Glotfelty. 00:00:22.250 --> 00:00:24.960 Today, we have several 00:00:24.960 --> 00:00:28.820 contested case items rulemaking projects to attend to. 00:00:28.820 --> 00:00:33.060 We will then go into closed session, take a break. 00:00:33.060 --> 00:00:34.930 And after that break, 00:00:34.930 --> 00:00:37.660 we will reconvene for the second half 00:00:37.660 --> 00:00:39.400 of today's programming, 00:00:39.400 --> 00:00:42.670 which is our work session to discuss market redesign 00:00:42.670 --> 00:00:45.253 under agenda item 18. 00:00:46.590 --> 00:00:49.620 So, that is our game plan for the day. 00:00:49.620 --> 00:00:50.453 And Mr. Janae, 00:00:50.453 --> 00:00:53.000 could you please walk us through today's Consent Agenda? 00:00:53.860 --> 00:00:56.260 Good morning, Commissioners by individual Gallup. 00:00:56.260 --> 00:00:58.960 The following items were placed on your Consent Agenda. 00:00:58.960 --> 00:01:01.220 7, 27 and 28. 00:01:01.220 --> 00:01:04.940 Commissioner Cobos is recused from item seven. 00:01:04.940 --> 00:01:05.773 Thank you, sir. 00:01:05.773 --> 00:01:06.820 Is there a motion to approve the items 00:01:06.820 --> 00:01:08.120 just described by Mr. Janae? 00:01:08.120 --> 00:01:10.150 So moved. Second 00:01:10.150 --> 00:01:11.160 All in favor, say aye. 00:01:11.160 --> 00:01:12.150 Aye. Aye. 00:01:12.150 --> 00:01:14.703 None opposed, the motion passes at this time. 00:01:15.560 --> 00:01:17.230 Like to open for public comment, 00:01:17.230 --> 00:01:19.780 or comments related to a specific agenda item will be heard 00:01:19.780 --> 00:01:21.100 when that item is taken up, 00:01:21.100 --> 00:01:23.210 this is for general comments only. 00:01:23.210 --> 00:01:26.222 Speakers will be limited to three minutes each. 00:01:26.222 --> 00:01:29.070 Mr. Janae, do we have anyone from the public 00:01:29.070 --> 00:01:29.903 signed up to speak? 00:01:29.903 --> 00:01:32.250 No one signed on the sheet, sir. 00:01:32.250 --> 00:01:33.133 Thank you, sir. 00:01:33.133 --> 00:01:36.340 In that case, public comment is now closed, 00:01:36.340 --> 00:01:41.090 we will not be taking up items four, 11, 14, 16, and 17, 00:01:41.090 --> 00:01:45.720 which brings us to our regular agenda. 00:01:45.720 --> 00:01:49.470 Mr. Janae, could you lay out our first item. 00:01:49.470 --> 00:01:52.750 Item one is Docket 50404, 00:01:52.750 --> 00:01:54.850 Petition Of Sterling Deason O'donnell 00:01:54.850 --> 00:01:59.573 and/or related entity to amend the Marilee SUD CCN 00:02:00.770 --> 00:02:02.300 by expedited release 00:02:02.300 --> 00:02:04.370 the Commission issued an order on October 12th. 00:02:04.370 --> 00:02:08.780 Marilee SUD filed a motion for rehearing on November 5th, 00:02:08.780 --> 00:02:11.500 we've asked y'all to extend time to act. 00:02:11.500 --> 00:02:13.330 Thank you, sir, seems pretty straightforward. 00:02:13.330 --> 00:02:14.300 Any thoughts, comments, 00:02:14.300 --> 00:02:17.790 or motion to extend time to act on the motion for rehearing 00:02:17.790 --> 00:02:20.280 before the maximum period about Labella? 00:02:20.280 --> 00:02:23.170 Yes, sir, I would move to extend time. 00:02:23.170 --> 00:02:24.370 Is there a second? 00:02:24.370 --> 00:02:25.370 Second. 00:02:25.370 --> 00:02:26.203 All in favor, say aye. 00:02:26.203 --> 00:02:27.150 Aye. Aye. 00:02:27.150 --> 00:02:29.029 None opposed, motion passes, next item, please. 00:02:29.029 --> 00:02:33.300 Item two is Docket 51545, Petition of Compass Datacenters 00:02:38.670 --> 00:02:43.310 to amend Rockett SUD CCN by expedited release 00:02:43.310 --> 00:02:46.700 the Commission issued an order on October 12th. 00:02:46.700 --> 00:02:49.410 The Rockett SUD filed a motion for rehearing 00:02:49.410 --> 00:02:51.420 on the November 5th, 00:02:51.420 --> 00:02:54.183 we've asked y'all to extend time to act on the motion. 00:02:55.740 --> 00:02:57.274 Thank you, sir. 00:02:57.274 --> 00:02:58.107 Who has comments 00:02:58.107 --> 00:03:00.410 or a motion similar set up, thoughts, comments, or motion 00:03:00.410 --> 00:03:02.950 to extend time to act on the motion for rehearing? 00:03:02.950 --> 00:03:05.263 I would allow it and move to extend time. 00:03:06.150 --> 00:03:07.251 And is there a second? 00:03:07.251 --> 00:03:08.084 Second. 00:03:09.260 --> 00:03:10.100 All in favor, say aye. 00:03:10.100 --> 00:03:11.610 Aye. Aye. 00:03:11.610 --> 00:03:13.403 None opposed, the motion passes. 00:03:14.430 --> 00:03:16.210 Item number three please. Mr.- 00:03:16.210 --> 00:03:18.670 Item three is Docket 52090, 00:03:18.670 --> 00:03:20.330 Petition of Redbird Development 00:03:20.330 --> 00:03:23.820 to Amend Dobbin Plantersville WFC certificate 00:03:23.820 --> 00:03:24.930 by expedited release 00:03:24.930 --> 00:03:27.320 the Commission issued an order on October 12th, 00:03:28.200 --> 00:03:30.390 Dobbin Plantersville WFC 00:03:30.390 --> 00:03:32.080 filed a motion rehearing on the 5th, 00:03:32.080 --> 00:03:34.710 we've asked you to extend time to act on the motion. 00:03:34.710 --> 00:03:37.060 Similar set up, thoughts, comments, motion 00:03:37.060 --> 00:03:39.770 to extend time to maximum rehearing 00:03:39.770 --> 00:03:41.610 to the maximum extent, blah, blah, blah. 00:03:41.610 --> 00:03:44.580 Same thing here on this one, I would need to extend. 00:03:44.580 --> 00:03:45.490 Is there a second. Second. 00:03:45.490 --> 00:03:46.490 All in favor, say aye. 00:03:46.490 --> 00:03:47.736 Aye. Aye. 00:03:47.736 --> 00:03:48.620 Aye. 00:03:48.620 --> 00:03:50.473 None opposed, motion passes. 00:03:53.050 --> 00:03:54.010 Getting the hang of this. 00:03:54.010 --> 00:03:58.110 All right, nothing on five and six, seven was consented, 00:03:58.110 --> 00:04:01.543 it brings us to item number eight. 00:04:05.830 --> 00:04:08.280 Item eight is Docket 52689, 00:04:08.280 --> 00:04:11.140 is the Expedited Petition of CenterPoint and others 00:04:11.140 --> 00:04:14.053 for a load management program and an accounting order. 00:04:15.050 --> 00:04:19.090 I will note that a revised agreement 00:04:19.090 --> 00:04:22.973 and other documents filed by the utility yesterday. 00:04:24.500 --> 00:04:25.730 Thank you, sir. 00:04:25.730 --> 00:04:28.060 As is something we've discussed before, 00:04:28.060 --> 00:04:29.850 you got a lot of feedback on that 00:04:29.850 --> 00:04:31.700 as much as you may know, Janae noted, 00:04:33.680 --> 00:04:37.220 a lot of the feedback was received yesterday 00:04:37.220 --> 00:04:40.392 leaving little time to fully vet. 00:04:40.392 --> 00:04:43.280 I know there were budget caps put in part of your requests. 00:04:43.280 --> 00:04:44.220 Yes, sir. 00:04:44.220 --> 00:04:45.820 But that being said a lot of things around here 00:04:45.820 --> 00:04:46.960 moving fast and furious, 00:04:46.960 --> 00:04:50.310 so far from the only ones falling things 00:04:50.310 --> 00:04:51.660 with little time to review. 00:04:54.986 --> 00:04:57.540 Two big things to consider, 00:04:57.540 --> 00:05:00.400 establishing establishment of the regulatory asset 00:05:00.400 --> 00:05:01.760 and then approval of the plans, 00:05:01.760 --> 00:05:04.433 I think we certainly want to, well, first of all, 00:05:04.433 --> 00:05:06.930 thank you for the feedback the TDUs and especially voltage 00:05:07.877 --> 00:05:10.350 and also ERCOT for their feedback 00:05:11.500 --> 00:05:13.750 and the input in response to the questions from the dyes. 00:05:13.750 --> 00:05:15.260 I think the regulatory asset 00:05:15.260 --> 00:05:16.960 certainly needs to be established. 00:05:17.940 --> 00:05:20.683 We need all the tools we can get this winter. 00:05:22.810 --> 00:05:24.083 The plans, 00:05:25.150 --> 00:05:28.163 I'm really curious to hear y'all's thoughts on today, 00:05:29.650 --> 00:05:31.230 I can see going both ways on those 00:05:31.230 --> 00:05:36.230 given the new nature of this and the tight timelines, 00:05:38.740 --> 00:05:39.573 but I certainly, 00:05:39.573 --> 00:05:43.000 think it's something the pricing is consistent with the IRS, 00:05:43.000 --> 00:05:44.020 it's similar to the framework, 00:05:44.020 --> 00:05:45.230 similar to our summer program, 00:05:45.230 --> 00:05:49.300 so, I think it's been helpful to see all of that laid out, 00:05:49.300 --> 00:05:52.420 well, clearly, it's helpful to have the budget caps, 00:05:52.420 --> 00:05:55.290 but would welcome your thoughts and comments. 00:05:55.290 --> 00:05:56.890 Yep, thank you, Chairman Lake. 00:05:57.750 --> 00:06:01.688 And I think your layout of the two main decision points 00:06:01.688 --> 00:06:03.253 is well set forth. 00:06:04.780 --> 00:06:07.210 With respect to the approval of the accounting order 00:06:07.210 --> 00:06:08.420 to establish a regulatory asset, 00:06:08.420 --> 00:06:12.010 I think that is an action we can take today, and should, 00:06:12.010 --> 00:06:15.340 as you described to allow the utilities 00:06:15.340 --> 00:06:18.840 to implement this program 00:06:18.840 --> 00:06:21.340 as sort of a testing bed for this upcoming winter. 00:06:22.240 --> 00:06:23.730 I would stop there. 00:06:23.730 --> 00:06:25.930 I think ultimately they will have to come in 00:06:25.930 --> 00:06:29.140 in their next rate case and justify their costs. 00:06:29.140 --> 00:06:32.070 And I don't know if I would get involved 00:06:32.070 --> 00:06:33.610 in actually approving all the specifics 00:06:33.610 --> 00:06:35.510 in their plan at this time. 00:06:35.510 --> 00:06:38.400 Okay, any thoughts, comments? 00:06:38.400 --> 00:06:40.450 Boy, that sounds like a prudent action. 00:06:42.200 --> 00:06:43.033 I like it. 00:06:43.930 --> 00:06:44.763 Just thought. 00:06:44.763 --> 00:06:46.050 The action part or the prudent part? 00:06:46.050 --> 00:06:47.087 Both. 00:06:47.087 --> 00:06:50.260 (members laughing) 00:06:50.260 --> 00:06:51.200 All right. 00:06:51.200 --> 00:06:54.870 I'm kind of the naysayer here, I don't like it. 00:06:54.870 --> 00:06:55.906 Any other? 00:06:55.906 --> 00:06:56.743 Prudence or the action? 00:06:56.743 --> 00:07:00.160 Well, I think it was thrown in at the last minute. 00:07:00.160 --> 00:07:03.910 We're trying to look at ECRF next year, 00:07:03.910 --> 00:07:07.510 we're trying, in my opinion, the market ought to be moving 00:07:07.510 --> 00:07:09.900 to a lot of these demand-response programs 00:07:09.900 --> 00:07:10.733 and the utilities 00:07:10.733 --> 00:07:14.260 ought to be using ECRF for energy efficiency. 00:07:14.260 --> 00:07:18.363 And I just feel if this was a real pilot program, 00:07:19.991 --> 00:07:22.030 it would be one and a half megawatts, 00:07:22.030 --> 00:07:23.700 10 megawatts and 20 megawatts. 00:07:23.700 --> 00:07:27.460 But what we have is one and a half, 10 and 300, 00:07:27.460 --> 00:07:28.770 that's a lot of megawatts. 00:07:28.770 --> 00:07:31.560 And I know service territories are very different. 00:07:31.560 --> 00:07:35.940 But I struggle that I don't think 00:07:35.940 --> 00:07:37.425 this is really just a pilot program. 00:07:37.425 --> 00:07:40.620 Does this become a full program 00:07:40.620 --> 00:07:45.380 that we end up integrating into something else 00:07:45.380 --> 00:07:46.520 without full discussion? 00:07:46.520 --> 00:07:49.043 Is it something that we change in three months, 00:07:50.540 --> 00:07:52.340 which doesn't really give certainty? 00:07:53.980 --> 00:07:55.010 So, those are the questions 00:07:55.010 --> 00:07:56.980 that I'm kind of wrangling with here 00:07:56.980 --> 00:08:01.980 on this kind of dropped, I think it was 11, when was this? 00:08:04.080 --> 00:08:05.410 When did we get this? 00:08:05.410 --> 00:08:06.723 Less than 30 days ago. 00:08:08.440 --> 00:08:09.273 So. 00:08:09.273 --> 00:08:11.700 All very fair concerns. 00:08:11.700 --> 00:08:13.730 Can I highlight something you said at the very beginning? 00:08:13.730 --> 00:08:14.563 You may. 00:08:14.563 --> 00:08:17.080 The demand response should be moving to the market, 00:08:17.080 --> 00:08:19.483 I think, is that the- <v ->That's what I said. 00:08:19.483 --> 00:08:23.860 And ECRF should be at the TDU level? 00:08:23.860 --> 00:08:25.350 That's what I believe. 00:08:25.350 --> 00:08:28.035 So, I wanna highlight that, I think that's exactly right, 00:08:28.035 --> 00:08:31.750 and I think that's where we need to move philosophically 00:08:31.750 --> 00:08:32.723 across the board. 00:08:34.230 --> 00:08:37.280 So, that's an, I think that's an incredibly important point 00:08:37.280 --> 00:08:42.140 that shouldn't go by the wayside. 00:08:42.140 --> 00:08:45.550 So, I agree with that, thank you for highlighting that. 00:08:45.550 --> 00:08:48.870 As for overgrown pilot program, 00:08:48.870 --> 00:08:53.790 that just becomes part of the, absorbed into the mass. 00:08:54.740 --> 00:08:57.990 I guess I'm thinking of this less as a pilot program 00:08:57.990 --> 00:09:02.990 than an effort to use every tool we've got this winter 00:09:05.820 --> 00:09:09.990 until we can get the broader reforms in place 00:09:09.990 --> 00:09:11.370 and implement it. 00:09:11.370 --> 00:09:13.170 So, I certainly don't think of this 00:09:13.170 --> 00:09:15.610 as something that is ongoing forever. 00:09:15.610 --> 00:09:16.443 Right. 00:09:17.800 --> 00:09:19.360 I don't recall, 00:09:19.360 --> 00:09:23.960 we've obviously all read a lot in the last couple of days, 00:09:23.960 --> 00:09:25.860 papers flying around. 00:09:25.860 --> 00:09:29.373 I also, if I recall, ERCOT had a problem implementing it. 00:09:30.630 --> 00:09:33.780 So, I have some question about that, 00:09:33.780 --> 00:09:38.090 but also would wonder if that is the case. 00:09:38.090 --> 00:09:40.070 And if they have a trouble implementing it, 00:09:40.070 --> 00:09:43.390 then again, how do we justify doing it? 00:09:43.390 --> 00:09:46.677 So, I noticed that as well, 00:09:46.677 --> 00:09:48.610 and if any action we take, 00:09:48.610 --> 00:09:52.290 I think we need to include ordering paragraphs 00:09:52.290 --> 00:09:53.580 to address that information, 00:09:53.580 --> 00:09:55.610 I think it's an information challenge for ERCOT. 00:09:55.610 --> 00:09:56.740 Right. 00:09:56.740 --> 00:09:57.573 Certainly to address that. 00:09:57.573 --> 00:10:00.730 Is that settlement issue as well? 00:10:00.730 --> 00:10:02.570 There's a pricing issue involved there. 00:10:02.570 --> 00:10:03.403 Yeah. 00:10:04.696 --> 00:10:09.696 Can that be addressed, or is that a lost order? 00:10:10.041 --> 00:10:11.480 That's why I have concerns, 00:10:11.480 --> 00:10:12.970 'cause I don't know if it can be addressed or not. 00:10:12.970 --> 00:10:14.050 I haven't heard anything from- 00:10:14.050 --> 00:10:18.167 I'm gonna ask, or whoever appropriate from ERCOT can. 00:10:27.640 --> 00:10:29.143 Kanaan Gallman with ERCOT. 00:10:30.320 --> 00:10:31.860 So, we currently 00:10:31.860 --> 00:10:36.860 don't digest the magnitude of these programs, 00:10:38.120 --> 00:10:40.770 and there's a request that we do a price adjustment 00:10:42.530 --> 00:10:44.650 for their deployment, 00:10:44.650 --> 00:10:48.620 and that's the area that we have a challenge in. 00:10:48.620 --> 00:10:50.730 So, it's a pricing issue 00:10:50.730 --> 00:10:55.130 as well as will flow all the way through to settlements. 00:10:55.130 --> 00:11:00.130 And I also think that doing the price correction by, 00:11:01.710 --> 00:11:03.280 say, January, 00:11:03.280 --> 00:11:08.280 really is not in our scope of work at this point. 00:11:10.240 --> 00:11:12.333 So, that would also be a challenge. 00:11:16.250 --> 00:11:19.707 So, I think that's the extent of the comments 00:11:19.707 --> 00:11:21.493 as I remembered them. 00:11:23.010 --> 00:11:25.713 Can't be done or would be really hard to do? 00:11:26.930 --> 00:11:29.300 Can't be done, okay. 00:11:29.300 --> 00:11:30.350 Just being honest there, Gallman, 00:11:30.350 --> 00:11:32.260 I mean, we're building a car at 60 miles per hour here, 00:11:32.260 --> 00:11:33.800 moving into this winter. 00:11:33.800 --> 00:11:37.030 Yeah, I mean that price adjustment component either, 00:11:37.030 --> 00:11:41.350 it's not that you can't implement what's been asked, 00:11:41.350 --> 00:11:46.350 it's the pricing adjustment that can't be done for January. 00:11:48.630 --> 00:11:50.210 Yeah. 00:11:50.210 --> 00:11:52.100 Can it be known if you had more time? 00:11:52.100 --> 00:11:53.633 Could you do it after January? 00:11:54.850 --> 00:11:58.040 We could, so, it is absolutely doable, 00:11:58.040 --> 00:11:59.140 it's technically doable, 00:11:59.140 --> 00:12:03.913 it's a matter of moving resources to implement that. 00:12:05.480 --> 00:12:07.100 Where are you gonna move resources from? 00:12:07.100 --> 00:12:07.990 I'm sorry, Commissioner. 00:12:07.990 --> 00:12:09.223 No. Don't apologize. 00:12:11.620 --> 00:12:12.460 So. 00:12:12.460 --> 00:12:14.393 Whatever the next thing is. 00:12:15.500 --> 00:12:20.500 It is not something we have designed at this point, 00:12:20.650 --> 00:12:25.420 that adjustment, and the resources that it would move 00:12:25.420 --> 00:12:27.290 are off of the settlement team 00:12:29.388 --> 00:12:31.750 and the market design team on that front. 00:12:31.750 --> 00:12:34.470 Which are focused on securitization 00:12:34.470 --> 00:12:36.080 and variety of other matters. 00:12:36.080 --> 00:12:36.913 Correct. 00:12:40.810 --> 00:12:42.410 Where does that leave you? 00:12:42.410 --> 00:12:46.240 That leaves me struggling with how we take resources 00:12:46.240 --> 00:12:49.240 off these more important projects to do something like this. 00:12:50.370 --> 00:12:52.313 And maybe there's another, 00:12:53.235 --> 00:12:55.460 a couple hundred megawatts we can find somewhere 00:12:55.460 --> 00:12:56.293 if we need it. 00:12:56.293 --> 00:12:59.140 But I struggle with implementing a new program very quickly 00:13:00.110 --> 00:13:01.710 knowing what we know from ERCOT. 00:13:04.864 --> 00:13:05.697 That's where I am. 00:13:05.697 --> 00:13:06.530 Can it be implemented? 00:13:06.530 --> 00:13:09.600 Can we get those megawatts without the price adjustment? 00:13:09.600 --> 00:13:13.653 Yeah, I mean, the proposal does not, 00:13:14.580 --> 00:13:18.300 in any way, tie itself to the price adjustment. 00:13:18.300 --> 00:13:22.060 I may be able to make a very clunky adjustment, 00:13:22.060 --> 00:13:26.440 but that might not align market conditions 00:13:26.440 --> 00:13:28.503 to the actual price. 00:13:29.460 --> 00:13:32.120 But you could get those megawatts, we just wouldn't be, 00:13:32.120 --> 00:13:34.370 the price adjustment would need to come later 00:13:34.370 --> 00:13:38.913 and the project schedule. 00:13:43.060 --> 00:13:44.570 Wait a moment, is that something- 00:13:44.570 --> 00:13:46.760 That would move me in the direction of saying, 00:13:46.760 --> 00:13:48.660 yeah, this is great, let's go forward. 00:13:49.738 --> 00:13:51.570 Okay, so, there's no scenario 00:13:51.570 --> 00:13:56.570 where this should move forward on this timeframe? 00:13:57.270 --> 00:13:59.490 Well, there could be, but I haven't heard it yet, 00:13:59.490 --> 00:14:00.770 to satisfy me. 00:14:00.770 --> 00:14:01.603 Okay, what. 00:14:02.760 --> 00:14:04.560 Well, I mean, the settlement issues are concerned, 00:14:04.560 --> 00:14:07.260 I don't know if we may need to hear from center point. 00:14:08.500 --> 00:14:10.140 So, and the key thing here, 00:14:10.140 --> 00:14:14.290 is it's not about settling the program, 00:14:14.290 --> 00:14:16.230 it's the price adjustment 00:14:16.230 --> 00:14:19.210 and settling the rest of the market, that is the issue. 00:14:19.210 --> 00:14:20.240 Yeah, absolutely. 00:14:20.240 --> 00:14:24.580 So, the proposals from the TDUs could all get implemented, 00:14:24.580 --> 00:14:28.243 that's not, we wouldn't be in the way of doing that. 00:14:30.090 --> 00:14:31.600 So, you've noted this issue 00:14:31.600 --> 00:14:33.220 from an implementation standpoint, 00:14:33.220 --> 00:14:35.540 and a TCPA has noted this 00:14:35.540 --> 00:14:38.923 from a impact on pricing for generation. 00:14:40.030 --> 00:14:42.170 Those are the two angles on this issue 00:14:42.170 --> 00:14:44.120 that I think have been presented to us. 00:14:48.380 --> 00:14:49.213 Good morning, 00:14:49.213 --> 00:14:51.000 Commissioner Sam Chang with CenterPoint Energy. 00:14:51.000 --> 00:14:52.880 Commissioner Glotfelty, just one clarification, 00:14:52.880 --> 00:14:55.160 as part of the revised settlement, we did agree 00:14:55.160 --> 00:14:58.920 to lower the 300 megawatt upper boundary to 150. 00:14:58.920 --> 00:15:00.550 Oh, okay, thank you. 00:15:00.550 --> 00:15:04.160 As it relates to information that ERCOT needs, 00:15:04.160 --> 00:15:06.720 I have been conferring with ERCOT's counsel 00:15:06.720 --> 00:15:08.300 regarding specific language. 00:15:08.300 --> 00:15:11.380 And I believe our caught provided some sample language 00:15:11.380 --> 00:15:14.403 in its comments and analysis, and we're happy 00:15:14.403 --> 00:15:16.220 to have the Commission incorporate that kind of language 00:15:16.220 --> 00:15:18.203 as it relates to information sharing. 00:15:19.080 --> 00:15:21.300 With regard to pricing those and price formation, 00:15:21.300 --> 00:15:23.910 that's really not ordeal, that's not part of our program, 00:15:23.910 --> 00:15:26.563 that's more of something KCPA raised. 00:15:29.670 --> 00:15:32.210 Which goes to demand response in the market. 00:15:32.210 --> 00:15:33.345 Right. 00:15:33.345 --> 00:15:34.262 And TDUs. 00:15:38.680 --> 00:15:40.833 Thoughts on how to resolve this? 00:15:42.950 --> 00:15:43.850 Yes, sir. 00:15:43.850 --> 00:15:46.030 Non-negotiable, I think, and I believe we're all there, 00:15:46.030 --> 00:15:48.300 we don't wanna siphon resources away 00:15:48.300 --> 00:15:52.143 from real-time, operational mechanics 00:15:53.990 --> 00:15:55.280 that are being worked through 00:15:55.280 --> 00:15:56.970 for the purposes of the winter. 00:15:56.970 --> 00:15:58.920 Because we need those megawatts 00:15:58.920 --> 00:16:02.540 that we know how they perform to perform as expected. 00:16:02.540 --> 00:16:03.373 Regular marking function. 00:16:03.373 --> 00:16:04.206 Yes, sir. 00:16:04.206 --> 00:16:05.500 Okay. 00:16:05.500 --> 00:16:08.380 So again, if, if Kanaan can tell us, 00:16:08.380 --> 00:16:11.570 which I believe he is, you can move forward 00:16:11.570 --> 00:16:14.030 to where this program and project 00:16:14.030 --> 00:16:17.050 will not disrupt the functions 00:16:17.050 --> 00:16:21.160 of the personnel associated with market operations. 00:16:21.160 --> 00:16:23.030 It will not siphon away resources, 00:16:23.030 --> 00:16:25.550 because I wanna count on the megawatts that I know 00:16:25.550 --> 00:16:27.160 are gonna be able to be there. 00:16:27.160 --> 00:16:30.170 So, I mean, I think the programs can go forward, 00:16:30.170 --> 00:16:31.610 it's just the price adjustment. 00:16:31.610 --> 00:16:35.800 Yeah. That was requested by TCPA, 00:16:35.800 --> 00:16:40.260 would not be able to go forward in the January timeframe. 00:16:40.260 --> 00:16:42.290 Later, and maybe clunky. 00:16:42.290 --> 00:16:43.123 Yes. 00:16:43.123 --> 00:16:47.630 And they've requested a series of other price corrections, 00:16:47.630 --> 00:16:49.660 and it could delay that, 00:16:49.660 --> 00:16:50.670 those are some other issues 00:16:50.670 --> 00:16:53.490 we'd have to have to talk through. 00:16:53.490 --> 00:16:58.490 But I think January is not a possibility, 00:16:59.640 --> 00:17:03.360 it puts at risk some of the other price corrections 00:17:03.360 --> 00:17:05.633 that were asked for this summer. 00:17:06.850 --> 00:17:08.730 Given the small amount of megawatts 00:17:08.730 --> 00:17:09.670 that we're talking about, 00:17:09.670 --> 00:17:13.230 I mean, how big of an impact is it on a price correction? 00:17:13.230 --> 00:17:16.423 Is it something significantly large? 00:17:18.020 --> 00:17:21.823 We're looking at maybe 170 megawatts or less. 00:17:22.900 --> 00:17:25.160 Well, low reserves that counts for a lot. 00:17:25.160 --> 00:17:29.680 Yeah, I would say if I'm far away from the steep part 00:17:29.680 --> 00:17:32.190 of the operating reserve demand curve, 00:17:32.190 --> 00:17:36.610 the impact is small, but these programs are most likely, 00:17:36.610 --> 00:17:40.630 gonna be deployed at the very edge 00:17:40.630 --> 00:17:42.790 of the operating reserve demand curve 00:17:42.790 --> 00:17:44.980 where the curve is extremely steep. 00:17:44.980 --> 00:17:49.980 So, even 100 megawatts can make a dramatic price change. 00:17:50.940 --> 00:17:55.160 Now, there's other price adjustments at play, 00:17:55.160 --> 00:17:58.260 and they may be sufficient 00:17:58.260 --> 00:18:03.160 to override what these programs do. 00:18:03.160 --> 00:18:08.160 And the proposal before you to change ORDC, 00:18:10.800 --> 00:18:13.763 may diminish that amount. 00:18:14.610 --> 00:18:19.203 So, you're thinking about increasing MCL 00:18:21.340 --> 00:18:24.820 and lowering HCAP, 00:18:24.820 --> 00:18:28.350 those things might make that impact much smaller, 00:18:28.350 --> 00:18:32.230 I have not studied those impacts. 00:18:32.230 --> 00:18:35.660 We can try and take a very quick look at that 00:18:35.660 --> 00:18:37.033 if it's helpful. 00:18:38.940 --> 00:18:43.157 Input from staff, and I suspect you've got some thoughts. 00:18:45.640 --> 00:18:47.340 Good morning, Chairman, Commissioners, 00:18:47.340 --> 00:18:49.310 Rustin Tawater for Commission staff, 00:18:49.310 --> 00:18:50.990 we continue to support the programs 00:18:50.990 --> 00:18:55.990 and echo what ERCOT and Mr. Chang from CenterPoint had said, 00:18:56.017 --> 00:18:58.130 that was one of the reasons why we couldn't agree 00:18:58.130 --> 00:19:01.980 to include the language the TPCA had suggested, 00:19:01.980 --> 00:19:04.130 because we weren't able to confirm with ERCOT 00:19:04.130 --> 00:19:05.920 that it would be workable, 00:19:05.920 --> 00:19:07.200 which is why ultimately, 00:19:07.200 --> 00:19:10.203 it didn't make it into the settlement that we signed on to. 00:19:11.990 --> 00:19:13.540 Rebecca, the Redbird Commission staff, 00:19:13.540 --> 00:19:17.090 there is an NPR that has been approved several years ago 00:19:17.090 --> 00:19:18.300 that would implement this. 00:19:18.300 --> 00:19:21.110 And through the ERCOT stakeholder PRS Project, 00:19:21.110 --> 00:19:23.690 I don't think it's something ERCOT has prioritized 00:19:23.690 --> 00:19:25.300 for implementation this time. 00:19:25.300 --> 00:19:27.130 It is dated and staff would support 00:19:27.130 --> 00:19:31.280 having that implemented ASAP as resources permit. 00:19:31.280 --> 00:19:33.190 I don't know if that's something y'all wanna consider 00:19:33.190 --> 00:19:35.590 delaying the capacity available for this winter. 00:19:38.000 --> 00:19:41.160 Thank you, Andreas Madrona for TCPA. 00:19:41.160 --> 00:19:43.350 And these are exactly the concerns we've raised, 00:19:43.350 --> 00:19:46.440 and the ERCOT just says exactly our concern. 00:19:46.440 --> 00:19:48.190 We don't know what the impact is, 00:19:48.190 --> 00:19:50.017 we don't know what the pricing impact is, 00:19:50.017 --> 00:19:52.110 and there hasn't been any analysis of that 00:19:52.110 --> 00:19:53.690 incorporated into this settlement, 00:19:53.690 --> 00:19:55.290 and that's what our concern was. 00:19:56.460 --> 00:19:59.310 We know we still have serious concerns about this 00:19:59.310 --> 00:20:01.210 because we don't know how it's gonna impact the prices, 00:20:01.210 --> 00:20:02.043 we don't know 00:20:02.043 --> 00:20:04.660 how it's gonna impact degeneration going forward, 00:20:04.660 --> 00:20:07.000 and the willingness to come in 00:20:07.000 --> 00:20:08.430 and further invest in this market 00:20:08.430 --> 00:20:09.997 if we keep on putting these programs 00:20:09.997 --> 00:20:12.640 where you have rate payer funded capacity 00:20:12.640 --> 00:20:14.940 essentially being paid in, 00:20:14.940 --> 00:20:16.460 as opposed to letting the market 00:20:16.460 --> 00:20:19.070 provide for this it's demand response. 00:20:19.070 --> 00:20:21.420 That said, we're, not gonna oppose the settlement, 00:20:21.420 --> 00:20:23.950 we want to leave this to the Commission, 00:20:23.950 --> 00:20:26.130 this is exactly the concerns that we have. 00:20:26.130 --> 00:20:28.700 And Director (indistinct) was completely correct 00:20:28.700 --> 00:20:32.850 that if NPR 1006 had been implemented, 00:20:32.850 --> 00:20:34.660 this would have been able to been accounted for. 00:20:34.660 --> 00:20:37.120 And that's, we had asked that that be done, 00:20:37.120 --> 00:20:39.410 and that this program and these programs 00:20:39.410 --> 00:20:41.880 could then be incorporated to that and we could know 00:20:41.880 --> 00:20:45.134 and tell you what we think the actual price impact would be. 00:20:45.134 --> 00:20:47.830 Unfortunately, because it hasn't been done, we can't. 00:20:47.830 --> 00:20:51.000 Perhaps one salient point that we need to focus on here, 00:20:51.000 --> 00:20:53.110 is that these pricing issues 00:20:53.110 --> 00:20:54.830 and pricing impacts will come into play 00:20:54.830 --> 00:20:57.897 if the load management programs are actually deployed. 00:20:57.897 --> 00:20:59.070 EA2. And EA2. 00:20:59.070 --> 00:21:01.350 So, we know we're doing everything we can 00:21:01.350 --> 00:21:03.257 to avoid emergency conditions, so. 00:21:04.285 --> 00:21:06.610 Which would be after the right payer 00:21:06.610 --> 00:21:09.680 funded ERs load management- That's right. 00:21:09.680 --> 00:21:11.720 Which we already do. 00:21:11.720 --> 00:21:13.693 Right. Very similar mechanism. 00:21:14.900 --> 00:21:17.120 So, in terms of distorting price formation, 00:21:17.120 --> 00:21:19.370 again, which we are going to depend on 00:21:19.370 --> 00:21:20.930 to incent the right behavior 00:21:20.930 --> 00:21:24.816 building into scarcity conditions that is less of a concern 00:21:24.816 --> 00:21:27.640 other than the impacts on forwards 00:21:27.640 --> 00:21:30.713 and how people are hedging, is that accurate? 00:21:31.900 --> 00:21:35.950 Break glass in case of emergency at 3000 PRC. 00:21:35.950 --> 00:21:37.400 Less. 00:21:37.400 --> 00:21:38.420 Lower. 00:21:38.420 --> 00:21:42.103 We're distorting the hell out of prices at 3000 MCL. 00:21:43.600 --> 00:21:44.970 And then when we deploy ERs, 00:21:44.970 --> 00:21:47.185 and then if EA2 is even lower than that, 00:21:47.185 --> 00:21:48.893 we've kind of crossed. 00:21:50.230 --> 00:21:52.770 As you often say, we were crossed that Rubicon 00:21:52.770 --> 00:21:53.920 well before we get EA2. 00:21:56.620 --> 00:21:59.070 Could I. 00:21:59.070 --> 00:21:59.903 I think. 00:22:02.160 --> 00:22:06.880 We have already said that if there is an EA2, 00:22:06.880 --> 00:22:08.190 there's load shed, 00:22:08.190 --> 00:22:11.490 and when there is load shed, the price is at the max. 00:22:11.490 --> 00:22:13.210 So, on the front end, 00:22:13.210 --> 00:22:15.580 you will get the price formation you need 00:22:15.580 --> 00:22:17.250 without an adjustment. 00:22:17.250 --> 00:22:20.950 Where this ends up being an issue, is on the backend. 00:22:20.950 --> 00:22:25.830 As the load is returning, it's not instantaneous, 00:22:25.830 --> 00:22:29.590 and that's where the adjustment would happen. 00:22:29.590 --> 00:22:34.590 So, we are halfway there already, 00:22:34.600 --> 00:22:37.673 it's that back half that there's some concern around. 00:22:42.670 --> 00:22:44.093 Somebody new stepped up. 00:22:45.802 --> 00:22:47.220 I just won't have all the resources at hand, 00:22:47.220 --> 00:22:48.820 if you have any other questions. 00:22:51.913 --> 00:22:52.963 Additional thoughts. 00:22:57.530 --> 00:22:59.090 Mr. Chairman, just, sorry to interrupt, 00:22:59.090 --> 00:23:00.340 just briefly on another point 00:23:00.340 --> 00:23:02.760 that Commissioner Glotfelty had made, 00:23:02.760 --> 00:23:06.090 we did have concerns about these costs 00:23:06.090 --> 00:23:08.570 and being able to review them for prudence later. 00:23:08.570 --> 00:23:11.330 We did include that term in the settlement and stipulation 00:23:11.330 --> 00:23:14.000 that any cost associated with these programs 00:23:14.000 --> 00:23:15.520 would be reviewed for reasonableness 00:23:15.520 --> 00:23:17.750 in the next base-rate proceeding. 00:23:17.750 --> 00:23:20.650 So, we will have an opportunity to go back and look 00:23:20.650 --> 00:23:22.550 after the programs have been deployed, 00:23:22.550 --> 00:23:24.720 if they are, which we hope. 00:23:24.720 --> 00:23:27.136 It's the only thing that makes me sleep at night. 00:23:27.136 --> 00:23:28.610 (members laughing) 00:23:28.610 --> 00:23:29.773 You sleep at night? 00:23:30.850 --> 00:23:33.635 Too much to do. A lot of dreams. 00:23:33.635 --> 00:23:34.487 Yes, ma'am. 00:23:34.487 --> 00:23:35.640 Hi, Carrie Collier-Brown 00:23:35.640 --> 00:23:37.490 with the Alliance for Retail Markets. 00:23:38.730 --> 00:23:42.110 We also signed on to the settlement, 00:23:42.110 --> 00:23:44.370 and thank everybody for working with us 00:23:44.370 --> 00:23:46.190 on the issues that had raised. 00:23:46.190 --> 00:23:49.120 And just wanted to bring to your attention 00:23:49.120 --> 00:23:52.780 that the three TDUs were part of this particular docket, 00:23:52.780 --> 00:23:55.980 but Oncor already also has a program 00:23:55.980 --> 00:23:57.750 that was within their EECRF 00:23:57.750 --> 00:24:00.300 that you guys approved at the last open meeting. 00:24:00.300 --> 00:24:02.230 And I think that you expressed, 00:24:02.230 --> 00:24:05.333 or we expressed, and we talked about last time, 00:24:06.520 --> 00:24:07.353 that it would be helpful 00:24:07.353 --> 00:24:10.180 if all of those programs are as consistent as possible. 00:24:10.180 --> 00:24:13.380 And for the reps, I think there's only one area 00:24:13.380 --> 00:24:17.810 where the three programs from AEP Oncor, or I'm sorry, 00:24:17.810 --> 00:24:21.850 AEP TNMP and CenterPoint differ from Oncor's program, 00:24:21.850 --> 00:24:25.370 is that Oncor's program does not provide for notification 00:24:25.370 --> 00:24:28.210 to the rep of record when their customer enrolls 00:24:28.210 --> 00:24:30.660 or is deployed under this program. 00:24:30.660 --> 00:24:33.880 And just wanted, I'd had some conversations with Oncor 00:24:35.150 --> 00:24:38.400 and I think that they probably need some guidance, 00:24:38.400 --> 00:24:41.110 or it'd be helpful to get some guidance from y'all 00:24:41.110 --> 00:24:45.310 on whether Oncor should also provide notification 00:24:45.310 --> 00:24:46.373 to the rep of record. 00:24:49.510 --> 00:24:53.500 Thank you, one more thing to work on. 00:24:53.500 --> 00:24:54.333 Yes, sir. 00:24:54.333 --> 00:24:56.303 Good morning, I'm Garry Jones with Oncor. 00:24:57.180 --> 00:24:59.030 If ordered by the Commission, 00:24:59.030 --> 00:25:02.780 we'll be happy to notify the reps 00:25:02.780 --> 00:25:04.600 and follow the side protocol. 00:25:04.600 --> 00:25:06.310 Do you have to be ordered? 00:25:06.310 --> 00:25:07.143 Yes. 00:25:11.610 --> 00:25:12.860 We'll make it. Okay. 00:25:15.370 --> 00:25:19.090 We'll put Mr. Janae, but for belts and suspenders, 00:25:19.090 --> 00:25:20.030 I think we'd all be comfortable 00:25:20.030 --> 00:25:23.143 ordering that notification of rep of record. 00:25:24.770 --> 00:25:28.583 All things considered with an order, 00:25:30.069 --> 00:25:32.670 a belt insist the Janae belt and suspenders order 00:25:32.670 --> 00:25:35.540 for notice of rep of record, 00:25:35.540 --> 00:25:40.350 including ordering paragraphs of notification to ERCOT, 00:25:40.350 --> 00:25:44.020 as ERCOT, the information sharing as ERCOT requested, 00:25:44.020 --> 00:25:49.020 we added those ordering paragraphs along those lines of, 00:25:50.360 --> 00:25:54.033 and I've got some language here that I'll lay out for you. 00:25:55.160 --> 00:25:57.810 With those two considerations initially, 00:25:57.810 --> 00:26:00.260 I'm okay moving forward with this 00:26:00.260 --> 00:26:02.910 with a third condition to your concerns 00:26:02.910 --> 00:26:07.050 that the Commission considers this winter only, 00:26:07.050 --> 00:26:12.050 and that ERCOT and staff work together 00:26:13.260 --> 00:26:18.260 to bring back a debrief on what timeframe. 00:26:24.160 --> 00:26:27.273 I could see how it worked by next July. 00:26:28.280 --> 00:26:30.220 I think that's workable. 00:26:30.220 --> 00:26:31.223 So, we can. 00:26:33.410 --> 00:26:36.580 And I mean, I almost want to say a kill switch like this. 00:26:36.580 --> 00:26:37.900 I don't know if we can put that in the ordering, 00:26:37.900 --> 00:26:41.850 but this is authorized for one time only, 00:26:41.850 --> 00:26:45.390 pending farther, I guess there's some (indistinct) 00:26:46.590 --> 00:26:47.423 I love this. 00:26:50.863 --> 00:26:52.010 How does that set? 00:26:52.010 --> 00:26:52.843 That works for me. 00:26:52.843 --> 00:26:55.770 I think the main thing that I was focused on, 00:26:55.770 --> 00:26:57.490 is just approving the accounting order, 00:26:57.490 --> 00:26:58.910 setting up the regulatory asset, 00:26:58.910 --> 00:27:00.910 letting the TDUs move forward 00:27:00.910 --> 00:27:04.190 as sort of a test run for this inter only, 00:27:04.190 --> 00:27:06.763 and then having a post-mortem. 00:27:08.485 --> 00:27:10.248 Yeah, that's it actually. 00:27:10.248 --> 00:27:11.413 I don't know where it came from. 00:27:11.413 --> 00:27:13.550 But, okay, so, doing that afterwards, 00:27:13.550 --> 00:27:17.373 the analysis to make sure that, just see how it worked out, 00:27:18.410 --> 00:27:20.300 and see if that's a program 00:27:20.300 --> 00:27:22.943 that I think that we can benefit from in the future, 00:27:24.840 --> 00:27:27.770 with respect to ordering Oncor to provide notice, 00:27:27.770 --> 00:27:29.856 I am happy to do that as well. 00:27:29.856 --> 00:27:30.689 Okay. 00:27:30.689 --> 00:27:33.540 Yes, so, approve the regulatory asset, 00:27:33.540 --> 00:27:35.090 establish the regulatory asset, 00:27:36.980 --> 00:27:39.960 not approve the plan was brutal part of the action. 00:27:39.960 --> 00:27:41.102 That's right. 00:27:41.102 --> 00:27:42.027 That's right. 00:27:42.027 --> 00:27:42.960 And who do you wanna order 00:27:42.960 --> 00:27:45.203 to give us something to do a post-mortem? 00:27:46.471 --> 00:27:48.520 I think the request was to Commission staff 00:27:48.520 --> 00:27:51.370 to work with ERCOT to provide that post-mortem, 00:27:51.370 --> 00:27:53.430 let's say June 1st. 00:27:53.430 --> 00:27:55.030 So, we'll have to work for going to the summer. 00:27:55.030 --> 00:27:55.863 Sure. 00:27:55.863 --> 00:27:57.330 Well, maybe the TDUs too, right? 00:27:57.330 --> 00:27:58.963 Since we'll have the data. 00:28:00.126 --> 00:28:03.760 Yeah, I think staff can work with ERCOT and the TDUs 00:28:03.760 --> 00:28:08.470 to provide an update and review of the program performance 00:28:08.470 --> 00:28:12.040 and capacity procured and pricing by June. 00:28:12.040 --> 00:28:13.330 Yeah, I think that's a good point, 00:28:13.330 --> 00:28:15.130 I'll hope that they would staff in ERCOT 00:28:15.130 --> 00:28:17.780 would receive all but cooperation and help they need. 00:28:20.700 --> 00:28:21.600 How does that sit? 00:28:22.520 --> 00:28:23.353 I know you don't like it, 00:28:23.353 --> 00:28:25.439 but would at least make you feel better? 00:28:25.439 --> 00:28:27.435 It makes me feel better when you pass it. 00:28:27.435 --> 00:28:30.352 (members laughing) 00:28:32.019 --> 00:28:35.131 All right, as for the paragraphs, 00:28:35.131 --> 00:28:39.640 awarding paragraphs related to notification to ERCOT, 00:28:39.640 --> 00:28:43.081 I'd offer for y'all's consideration, 00:28:43.081 --> 00:28:45.570 the first paragraph that each TDU must notify ERCOT 00:28:45.570 --> 00:28:47.950 the TDUs total procured load management capacity 00:28:47.950 --> 00:28:50.850 at least one business day before the start of the program. 00:28:51.940 --> 00:28:54.890 And each TDU must update ERCOT 00:28:54.890 --> 00:28:57.950 as to the impact on the TDU initiative deployments 00:28:57.950 --> 00:28:59.840 on the amount of load management capacity 00:28:59.840 --> 00:29:01.750 and deployment hours remaining. 00:29:01.750 --> 00:29:05.980 So, our God knows what's going on when it's going on. 00:29:05.980 --> 00:29:08.170 Does that language work for you? 00:29:08.170 --> 00:29:09.170 Agreeable. Yes. 00:29:10.950 --> 00:29:12.258 And. 00:29:12.258 --> 00:29:15.470 All right, is there a motion 00:29:15.470 --> 00:29:18.250 to issue an order to authorize the TDUs 00:29:18.250 --> 00:29:20.960 to establish a regulatory asset to record reasonable costs 00:29:20.960 --> 00:29:24.010 associated with their respective load managements 00:29:24.010 --> 00:29:27.500 with the inclusion of the two ordering paragraphs 00:29:27.500 --> 00:29:28.713 as I just laid out? 00:29:29.620 --> 00:29:34.080 And in order to Oncor to provide a notice of rep of record 00:29:35.560 --> 00:29:38.700 and direction to staff to work with ERCOT 00:29:38.700 --> 00:29:42.183 to provide a postmortem analysis by June 1st, 2022 00:29:44.020 --> 00:29:49.020 with acknowledgement that this is a one-time 00:29:49.690 --> 00:29:53.040 this-winter-only deployment, 00:29:53.040 --> 00:29:56.000 and in the absence of further action from the Commission 00:29:56.000 --> 00:30:00.640 will not be an ongoing program. 00:30:01.810 --> 00:30:04.470 So, I would suggest you modify your motion 00:30:04.470 --> 00:30:05.740 to limit the costs 00:30:05.740 --> 00:30:07.750 that can be included in a regulatory asset 00:30:07.750 --> 00:30:09.233 to cost incurred before. 00:30:11.730 --> 00:30:14.330 I believe they said this was going to February 28th. 00:30:15.240 --> 00:30:16.760 So that no cost after that day 00:30:16.760 --> 00:30:18.290 can be included in the regulatory asset, 00:30:18.290 --> 00:30:21.823 I think that will stop the program moving forward. 00:30:24.040 --> 00:30:27.450 We'll include that in any motion offered, 00:30:27.450 --> 00:30:29.700 is there such a motion? 00:30:29.700 --> 00:30:30.533 So moved. 00:30:30.533 --> 00:30:31.500 Second. 00:30:31.500 --> 00:30:32.680 All in favor, say, aye. 00:30:32.680 --> 00:30:33.513 Aye. 00:30:33.513 --> 00:30:34.720 Aye. Aye, any opposed? 00:30:34.720 --> 00:30:35.553 No. 00:30:36.900 --> 00:30:38.053 Motion passes. 00:30:39.449 --> 00:30:40.449 Thank you very much. 00:30:46.290 --> 00:30:50.570 Next up, item number nine, Mr. Janae. 00:30:50.570 --> 00:30:52.960 Item nine is project 38533. 00:30:52.960 --> 00:30:55.690 It's the PUC review of ERCOT budget, 00:30:55.690 --> 00:30:58.470 Commission staff has filed a memo with a proposed order 00:30:58.470 --> 00:31:00.383 on the November 30th. 00:31:03.010 --> 00:31:04.340 Thank you, sir. 00:31:04.340 --> 00:31:05.763 We've got a, 00:31:07.207 --> 00:31:09.970 as Mr. Janae has said, we gotta a memo file, 00:31:09.970 --> 00:31:14.803 addresses 2022, 2023 budget system administration fee, 00:31:15.790 --> 00:31:18.250 any updates cases, 00:31:18.250 --> 00:31:21.110 any questions, comments on the side of that. 00:31:22.294 --> 00:31:23.127 There you go. 00:31:24.540 --> 00:31:25.373 Comments here. 00:31:25.373 --> 00:31:26.206 Yes, sir. 00:31:26.206 --> 00:31:30.300 So, I support the budget approval 00:31:31.340 --> 00:31:34.893 with a caveat that since I'm fairly new at this, 00:31:36.210 --> 00:31:37.910 but have spent time with RTOs 00:31:37.910 --> 00:31:40.410 all across the country for many years, 00:31:40.410 --> 00:31:43.130 I believe that they get bloated 00:31:43.130 --> 00:31:45.560 and get extraordinary expenses 00:31:45.560 --> 00:31:48.530 and have a very poor record of doing metrics 00:31:48.530 --> 00:31:51.440 to determine their success for the market, 00:31:51.440 --> 00:31:56.090 for doing timelines for individual processes. 00:31:56.090 --> 00:31:59.430 And hope that we can work with a new board 00:32:00.450 --> 00:32:03.490 in an effort to find some set of metrics 00:32:03.490 --> 00:32:05.420 that we can all agree to 00:32:05.420 --> 00:32:08.760 that can be better informative to us and to all stakeholders 00:32:08.760 --> 00:32:11.710 on not only the market metrics, 00:32:11.710 --> 00:32:13.390 which I think they do a good job of, 00:32:13.390 --> 00:32:15.110 but the ERCOT performance metrics 00:32:15.110 --> 00:32:18.340 that I think are important for me to understand, 00:32:18.340 --> 00:32:20.140 that's a pretty important input 00:32:20.140 --> 00:32:21.840 into budgets going forward for me. 00:32:23.480 --> 00:32:25.407 Well put, couldn't say it better, 00:32:25.407 --> 00:32:26.960 and I'm glad that we're keeping 00:32:26.960 --> 00:32:30.083 the system administration fee flat for the time being, 00:32:30.950 --> 00:32:33.130 and I know the new board 00:32:33.130 --> 00:32:38.130 would welcome your input on sorting out all of those issues 00:32:39.380 --> 00:32:41.833 and working to optimize the organization. 00:32:43.600 --> 00:32:45.080 Any other thoughts, comments? 00:32:45.080 --> 00:32:48.580 Yeah, so, I support the approval of the budget. 00:32:48.580 --> 00:32:53.580 And I also would like to make some comments 00:32:53.810 --> 00:32:56.080 with respect to the tremendous amount of work 00:32:56.080 --> 00:32:59.840 that ERCOT has on their plate, a growing amount of work. 00:32:59.840 --> 00:33:01.580 Not only through all of the projects 00:33:01.580 --> 00:33:03.063 that they prioritize now, 00:33:04.020 --> 00:33:06.070 finishing the implementation of securitization, 00:33:06.070 --> 00:33:08.380 any market design, implementation 00:33:08.380 --> 00:33:12.200 that we direct them to complete. 00:33:12.200 --> 00:33:16.550 And I just really wanted to stay mindful and vigilant 00:33:16.550 --> 00:33:18.737 that we cannot let the ERCOT budget 00:33:18.737 --> 00:33:22.540 and their lack of resources or inability to hire staff 00:33:22.540 --> 00:33:27.540 get in the way of our tremendous, consistent 00:33:28.080 --> 00:33:32.520 and strong efforts to maintain grid reliability. 00:33:32.520 --> 00:33:35.210 And so, that we've had ongoing discussions 00:33:35.210 --> 00:33:40.210 about the impacts on settlement staff, the EMS upgrade, 00:33:40.980 --> 00:33:44.840 we're keeping this staff fee flat, that's great. 00:33:44.840 --> 00:33:49.840 But at the same time, if there is a need to hire more staff, 00:33:50.780 --> 00:33:53.738 if there is a need to hire contractors, 00:33:53.738 --> 00:33:57.290 I really would like to strongly encourage ERCOT 00:33:57.290 --> 00:34:01.510 to continue to communicate with their board and with us 00:34:01.510 --> 00:34:06.510 because we cannot let you know staff shortages 00:34:07.150 --> 00:34:08.600 or anything get in the way 00:34:08.600 --> 00:34:11.020 of us maintaining rigor liability. 00:34:11.020 --> 00:34:12.530 Because we heard over and over, 00:34:12.530 --> 00:34:14.416 the EMS upgrade it's taken a while, 00:34:14.416 --> 00:34:16.170 it's on time, it's under budget, 00:34:16.170 --> 00:34:19.660 but it's got to stay on time, it has to stay under budget, 00:34:19.660 --> 00:34:23.540 it is essentially a big project 00:34:23.540 --> 00:34:25.050 in the middle of our market redesign 00:34:25.050 --> 00:34:26.700 that we're having to work around, 00:34:27.950 --> 00:34:30.640 any other proposals that we ultimately adopt 00:34:30.640 --> 00:34:32.787 will have an impact on settlement staff 00:34:32.787 --> 00:34:34.950 and that's going to cause delays too. 00:34:34.950 --> 00:34:37.040 So, I just want to make sure 00:34:37.040 --> 00:34:41.910 that ERCOT is doing everything they can to get resources, 00:34:41.910 --> 00:34:43.770 to address these high, 00:34:43.770 --> 00:34:46.750 extremely, critically important high-priority items. 00:34:46.750 --> 00:34:47.583 The other thing, 00:34:47.583 --> 00:34:49.070 kind of a minor issue that I wanted to bring up, 00:34:49.070 --> 00:34:51.810 I noted in the correspondence 00:34:51.810 --> 00:34:53.510 that we reviewed for this meeting 00:34:53.510 --> 00:34:56.230 that ERCOT experiencing new demands 00:34:56.230 --> 00:34:58.240 related weatherization stability assessments 00:34:58.240 --> 00:34:59.760 for interconnecting generators, 00:34:59.760 --> 00:35:02.483 interconnection study increases in grid forecasting. 00:35:03.547 --> 00:35:05.570 As a matter of due diligence 00:35:05.570 --> 00:35:10.570 to look for other streams of revenue, 00:35:10.650 --> 00:35:12.530 I would like for ERCOT to evaluate 00:35:12.530 --> 00:35:16.360 whether the interconnection study fees should be increased 00:35:16.360 --> 00:35:18.800 and any fees that should be increased, 00:35:18.800 --> 00:35:20.670 because if they're under a tremendous amount of pressure 00:35:20.670 --> 00:35:23.920 to conduct interconnection studies, 00:35:23.920 --> 00:35:27.083 we wanna make sure that that fee is appropriate. 00:35:27.930 --> 00:35:28.763 Yeah, absolutely. 00:35:28.763 --> 00:35:31.297 I have heard that they are low in ERCOT. 00:35:31.297 --> 00:35:32.840 More barriers to entry, 00:35:32.840 --> 00:35:34.952 we don't want too high barrier to entry. 00:35:34.952 --> 00:35:35.785 Right. 00:35:35.785 --> 00:35:37.171 But we want some barrier to the entry. 00:35:37.171 --> 00:35:38.630 But we wanna make sure that we're up to parody 00:35:38.630 --> 00:35:40.983 with the other ISOs and RTOs. 00:35:42.570 --> 00:35:43.403 Agreed. 00:35:44.750 --> 00:35:45.680 Like any organization, 00:35:45.680 --> 00:35:48.020 it's a balance between having the resources you need 00:35:48.020 --> 00:35:51.723 without being bloated and inefficient, 00:35:53.854 --> 00:35:55.280 that's challenging the organization, 00:35:55.280 --> 00:35:58.870 and I agree that that needs to be looked at, 00:35:58.870 --> 00:36:02.090 and I'm sure the new board would also welcome your input 00:36:02.090 --> 00:36:04.253 on that kind of improvement. 00:36:05.650 --> 00:36:10.573 And like we've all got a board meeting next week. 00:36:11.820 --> 00:36:15.130 So, I know the new board will welcome all of this input 00:36:15.130 --> 00:36:19.660 and we'll work to optimize that organization. 00:36:19.660 --> 00:36:21.513 We don't wanna gut it, and we don't want it bloat it, 00:36:21.513 --> 00:36:22.346 we need to make it 00:36:22.346 --> 00:36:24.980 the highest performing organization it can be 00:36:24.980 --> 00:36:28.653 to deliver the services required for citizens in ERCOT. 00:36:30.960 --> 00:36:32.560 All right. 00:36:32.560 --> 00:36:34.490 One last comment, Mr. Shawn, 00:36:34.490 --> 00:36:35.580 I appreciated the opportunity 00:36:35.580 --> 00:36:37.410 to be able to speak to the ERCOT budget. 00:36:37.410 --> 00:36:40.460 I think that the fact that we are discussing it here 00:36:40.460 --> 00:36:43.070 signals that the Commission is going to be more active, 00:36:43.070 --> 00:36:44.990 especially in this period 00:36:44.990 --> 00:36:47.260 where the board is orienting itself 00:36:47.260 --> 00:36:50.550 to the governance of ERCOT, subject to SB 2. 00:36:50.550 --> 00:36:52.053 So, this budget, 00:36:53.380 --> 00:36:57.280 gratefully, ERCOT staff has organized it in a way 00:36:57.280 --> 00:37:00.120 where we can maintain the current feed levels, 00:37:00.120 --> 00:37:02.820 but in the future, make a good faith assessment 00:37:02.820 --> 00:37:04.700 of what those needs need to be moving forward, 00:37:04.700 --> 00:37:08.524 especially in light of any type of redesign 00:37:08.524 --> 00:37:13.470 and reform effort directed from the Commission. 00:37:13.470 --> 00:37:16.510 I think we need to be diligent 00:37:16.510 --> 00:37:20.621 and proactive with ERCOT staff 00:37:20.621 --> 00:37:22.960 and what those individual programs are 00:37:22.960 --> 00:37:25.890 and those individual costs associated with them. 00:37:25.890 --> 00:37:27.730 We have all been active in this process, 00:37:27.730 --> 00:37:31.883 leading up on those top-line issues that they look at EMS, 00:37:32.940 --> 00:37:34.970 all of the settlement functions 00:37:34.970 --> 00:37:36.380 in the settlement engine, moving forward. 00:37:36.380 --> 00:37:39.120 Anything that would delay any type of reform effort, 00:37:39.120 --> 00:37:42.690 but we're about to go into the weeds of reform now. 00:37:42.690 --> 00:37:44.680 I mean, we're gonna transition to phase two, 00:37:44.680 --> 00:37:46.120 which is implementation. 00:37:46.120 --> 00:37:48.210 So, I appreciate the opportunity 00:37:48.210 --> 00:37:51.050 to be diligent about what they need moving forward 00:37:51.050 --> 00:37:52.860 and how much this is really gonna cost. 00:37:52.860 --> 00:37:56.303 But in the past, under the deregulated construct, 00:37:57.210 --> 00:38:02.210 we were able to bless more in the ERCOT budget, 00:38:02.670 --> 00:38:03.690 but now, we're talking 00:38:03.690 --> 00:38:08.690 about un-bundling a lot of regulatory functions 00:38:09.020 --> 00:38:14.020 into more granular, specific ancillary service functions. 00:38:14.290 --> 00:38:15.950 So, that's gonna incur costs, 00:38:15.950 --> 00:38:18.470 that's gonna incur staff time to manage that. 00:38:18.470 --> 00:38:21.370 Because again, the system becomes more proactive 00:38:21.370 --> 00:38:23.150 rather than just reactive 00:38:23.150 --> 00:38:26.180 to the way market participants behave 00:38:26.180 --> 00:38:29.140 and the way all these products act together. 00:38:29.140 --> 00:38:33.080 So, with that, I am comfortable with this budget, 00:38:33.080 --> 00:38:35.770 appreciate the work that has gone into it at staff level 00:38:35.770 --> 00:38:39.477 in both agencies, both ERCOT and PUC, 00:38:39.477 --> 00:38:41.490 and look forward to it's approval. 00:38:41.490 --> 00:38:42.323 Thank you. 00:38:44.373 --> 00:38:47.950 Is there a motion to approve the proposed order? 00:38:47.950 --> 00:38:49.100 So moved. 00:38:49.100 --> 00:38:50.460 Second. 00:38:50.460 --> 00:38:51.293 All in favor, say, aye. 00:38:51.293 --> 00:38:52.900 Aye. Aye. 00:38:52.900 --> 00:38:55.200 None opposed, motion passes, thank you, Casey. 00:38:56.200 --> 00:38:57.603 Next item, please. 00:39:00.200 --> 00:39:03.700 Item 10 is project 501830, is review 00:39:03.700 --> 00:39:07.990 of certain retail electric customer protection rules, 00:39:07.990 --> 00:39:11.423 I believe the memo was filed 2nd November. 00:39:15.620 --> 00:39:16.453 Mr. Smeltzer. 00:39:18.031 --> 00:39:18.864 Good morning, Commissioners, 00:39:18.864 --> 00:39:20.130 David Smeltzer, Commission staff. 00:39:23.180 --> 00:39:25.130 This is, as you know, the rulemaking 00:39:25.130 --> 00:39:28.850 that started off with the premise of implementing HB 16, 00:39:28.850 --> 00:39:32.020 which is the ban on wholesale index prices in our market 00:39:32.020 --> 00:39:35.100 As part of developing this rulemaking, you asked us to, 00:39:35.100 --> 00:39:38.870 and we did include a few additional customer protections 00:39:38.870 --> 00:39:40.570 and also a few briefing questions. 00:39:41.840 --> 00:39:43.790 With the tight schedule we've had, 00:39:43.790 --> 00:39:45.330 this rule's a little bit behind 00:39:45.330 --> 00:39:46.440 where we would like it to have been, 00:39:46.440 --> 00:39:47.880 but if we're going to change the polar rate, 00:39:47.880 --> 00:39:52.690 it would be good to do that by next year when it resets. 00:39:52.690 --> 00:39:55.380 And so, and able to allow us 00:39:55.380 --> 00:39:57.650 to get it right on the first try for next open meeting, 00:39:57.650 --> 00:39:58.960 we filed a few brief questions. 00:39:58.960 --> 00:40:01.980 Should you have any input on any of them? 00:40:01.980 --> 00:40:02.813 We're happy to hear it, 00:40:02.813 --> 00:40:06.210 if not, we can proceed under our best judgment. 00:40:06.210 --> 00:40:08.180 But these were sort of the big policy questions 00:40:08.180 --> 00:40:09.360 that Commissioner Cobos 00:40:09.360 --> 00:40:10.890 in particular assets to file questions on, 00:40:10.890 --> 00:40:14.930 but willing to hear input from anyone who may have it. 00:40:14.930 --> 00:40:16.210 I'm happy to walk you guys through those, 00:40:16.210 --> 00:40:17.943 or you have the memo. 00:40:18.880 --> 00:40:19.713 Yeah. 00:40:19.713 --> 00:40:21.700 I don't know if this is something you've spent a lot of, 00:40:21.700 --> 00:40:22.960 or this area of the market 00:40:22.960 --> 00:40:24.510 is something you spent a lot of time on, 00:40:24.510 --> 00:40:27.530 so, happy to defer to you to take the lead on this. 00:40:27.530 --> 00:40:28.800 Okay. 00:40:28.800 --> 00:40:31.990 David, I think would be most helpful to go issue by issue 00:40:31.990 --> 00:40:34.240 and just kind of give us the context 00:40:34.240 --> 00:40:35.860 and then we can have a discussion 00:40:35.860 --> 00:40:38.270 and give you direction on issue by issue, 00:40:38.270 --> 00:40:39.500 or question by question there. 00:40:39.500 --> 00:40:40.620 Sure. 00:40:40.620 --> 00:40:43.620 So, the first issue is when we, 00:40:43.620 --> 00:40:46.350 staff's proposal for what the polar rate should be 00:40:46.350 --> 00:40:51.220 was to get out the realtime price component of it 00:40:52.150 --> 00:40:54.160 the project team had proposed 00:40:54.160 --> 00:40:56.350 going back and looking at the prior year 00:40:56.350 --> 00:40:58.650 and getting an average of the wholesale price for that year. 00:40:58.650 --> 00:40:59.790 So, it was still somewhat key 00:40:59.790 --> 00:41:02.190 to what's going on in the market, 00:41:02.190 --> 00:41:04.070 but then give a 20% increase on that 00:41:04.070 --> 00:41:06.020 for the added risk that a rep takes 00:41:06.020 --> 00:41:09.180 for the potential that they could have to assume 00:41:09.180 --> 00:41:10.880 a large customer base all at once. 00:41:11.986 --> 00:41:14.020 The first, one of the questions that you'd asked us to ask 00:41:14.020 --> 00:41:16.440 was, well, if there spikes or anything, 00:41:16.440 --> 00:41:18.430 do we need a year-over-year protection 00:41:18.430 --> 00:41:21.730 to prevent it from increasing more than a certain amount? 00:41:21.730 --> 00:41:24.130 Should that be the case? 00:41:24.130 --> 00:41:25.743 That's the policy issue. 00:41:27.806 --> 00:41:29.710 And I think, so, on one side of it, 00:41:29.710 --> 00:41:31.190 the customer protection aspect of it, 00:41:31.190 --> 00:41:33.750 on the other side of it, I think that the would argue, hey, 00:41:33.750 --> 00:41:36.110 the customers are only here for one month 00:41:36.110 --> 00:41:37.240 and they can change if they don't like it. 00:41:37.240 --> 00:41:41.320 So, I think this is a just sort of a high-level 00:41:41.320 --> 00:41:42.350 sort of policy question 00:41:42.350 --> 00:41:44.573 for how we want polar rates to function. 00:41:45.600 --> 00:41:46.433 So, yes. 00:41:46.433 --> 00:41:47.500 And as I had explained 00:41:47.500 --> 00:41:49.900 at the prior open meeting back in July, 00:41:49.900 --> 00:41:53.530 this issue is a balance between protecting customers 00:41:53.530 --> 00:41:55.210 and helping to ensure that the reps 00:41:55.210 --> 00:41:57.430 who have to bring on new customers 00:41:57.430 --> 00:41:59.550 as a result of a mass transition 00:42:01.930 --> 00:42:04.900 are not financial impacted by serving as a polar, 00:42:04.900 --> 00:42:06.020 provider of last resort. 00:42:06.020 --> 00:42:07.540 And so, what I had suggested, 00:42:07.540 --> 00:42:09.340 was including a safety threshold 00:42:10.200 --> 00:42:13.010 so that we can further protect consumers 00:42:13.010 --> 00:42:15.220 from swings and real-time settlement point prices. 00:42:15.220 --> 00:42:17.760 As you may recall from Winter Storm Uri, 00:42:17.760 --> 00:42:18.880 that was a tremendous impact 00:42:18.880 --> 00:42:21.490 because of the wholesale price index plans 00:42:21.490 --> 00:42:25.340 that were being delivered at the time. 00:42:25.340 --> 00:42:28.750 And so, the safety threshold that I had presented 00:42:28.750 --> 00:42:30.160 would provide additional protections 00:42:30.160 --> 00:42:32.570 to help ensure that consumers are further protected 00:42:32.570 --> 00:42:35.600 from significant swings in time settlement point prices. 00:42:35.600 --> 00:42:37.210 So, I had thought about putting, 00:42:37.210 --> 00:42:39.090 maybe like some kind of a percentage. 00:42:39.090 --> 00:42:42.420 At the time, I didn't have an exact one, 00:42:42.420 --> 00:42:46.070 I think for example, I put one out there, maybe 5%, 00:42:46.070 --> 00:42:49.150 just as an added protection in case we were to have a year 00:42:49.150 --> 00:42:52.253 where real-time settlement point of prices were very high. 00:42:54.150 --> 00:42:55.790 So, that's the way I laid out the issue. 00:42:55.790 --> 00:42:59.890 I continued to support a safety threshold, 00:42:59.890 --> 00:43:01.520 I think is as a matter of due diligence 00:43:01.520 --> 00:43:03.150 for further protection for the consumers, 00:43:03.150 --> 00:43:05.013 and I'd be happy to hear your thoughts. 00:43:05.950 --> 00:43:07.563 So, which threshold are you? 00:43:09.200 --> 00:43:13.478 I mean, we could start it at 5% from year to year, 00:43:13.478 --> 00:43:15.160 that was sort of what I had put out there, 00:43:15.160 --> 00:43:18.963 it's a percentage safety threshold. 00:43:20.250 --> 00:43:21.083 And staffs. 00:43:23.310 --> 00:43:26.300 The staff have a benchmark. 00:43:26.300 --> 00:43:30.910 I think the cap that was discussed 00:43:30.910 --> 00:43:33.530 quite a bit in the comments was 20%. 00:43:33.530 --> 00:43:34.363 And now I guess, 00:43:34.363 --> 00:43:38.040 to the price premium for the polar calculation. 00:43:38.040 --> 00:43:41.540 And so, that's what we were working with 00:43:41.540 --> 00:43:44.530 and would put in our recommendation absent 00:43:44.530 --> 00:43:45.850 for other direction. 00:43:45.850 --> 00:43:46.683 Okay. 00:43:46.683 --> 00:43:49.490 And that's based on stakeholder comment and your analysis, 00:43:49.490 --> 00:43:53.200 and I'm happy to consider that as a good point. 00:43:53.200 --> 00:43:54.033 Okay. 00:43:54.033 --> 00:43:57.033 And that seems like a good starting point, 00:43:57.960 --> 00:43:59.250 thank you for laying that out. 00:43:59.250 --> 00:44:02.803 Other thoughts and comments on the first issue at hand? 00:44:03.860 --> 00:44:05.250 Yeah. 00:44:05.250 --> 00:44:10.240 So, it'll come up later as we move through the questions, 00:44:10.240 --> 00:44:15.240 but I think the bill was specifically designed, 00:44:15.620 --> 00:44:18.880 and I've engaged with one of the authors, 00:44:18.880 --> 00:44:22.573 I'm not gonna say which, to perceive legislative intent. 00:44:25.420 --> 00:44:28.960 They want us to continue to have flexibility in the market 00:44:28.960 --> 00:44:29.793 to an extent. 00:44:29.793 --> 00:44:31.630 They want us to address the problems 00:44:31.630 --> 00:44:34.000 that were identified certainly, 00:44:34.000 --> 00:44:36.330 but they don't want everything to be a nail 00:44:36.330 --> 00:44:39.610 to where we tack it down so rigidly 00:44:39.610 --> 00:44:41.400 that there is no flexibility 00:44:41.400 --> 00:44:46.400 for the retail middlemen to negotiate better value 00:44:46.650 --> 00:44:51.430 for the consumer disclosed value, known value, 00:44:51.430 --> 00:44:53.510 rather than fixed means fixed. 00:44:53.510 --> 00:44:57.280 But as long as you sign off 00:44:57.280 --> 00:44:59.010 and you kind of understand the parameters 00:44:59.010 --> 00:45:01.960 of what you're agreeing to, is transparency in contracting. 00:45:03.980 --> 00:45:07.910 But let's stay on topic one and we'll debate that. 00:45:07.910 --> 00:45:12.910 So, my point is caps sometimes have a distorting effect 00:45:13.060 --> 00:45:15.353 in retail markets. 00:45:17.250 --> 00:45:21.140 And again, it wasn't addressed necessarily in the statute. 00:45:21.140 --> 00:45:25.450 So, at this time, but again, Commissioner, I bow, 00:45:25.450 --> 00:45:29.540 your interest in protecting the consumer is paramount, 00:45:29.540 --> 00:45:32.213 but at this time, 00:45:33.700 --> 00:45:36.650 if it's not in the directive from the legislature, 00:45:36.650 --> 00:45:38.280 should we impose this cap now, 00:45:38.280 --> 00:45:40.283 or readdress it moving forward? 00:45:41.580 --> 00:45:42.490 What are your thoughts? 00:45:42.490 --> 00:45:46.250 Well, and thank you for speaking to legislative intent. 00:45:46.250 --> 00:45:48.860 When I look at legislation, I read the letter of the law, 00:45:48.860 --> 00:45:50.480 that that's what we have to do. 00:45:50.480 --> 00:45:54.610 And so, with respect to HB 16, 00:45:54.610 --> 00:45:57.440 there is specific language in there 00:45:57.440 --> 00:46:00.900 that states that no provision in Piera 391110 00:46:00.900 --> 00:46:02.650 shall be construed to prohibit the Commission 00:46:02.650 --> 00:46:03.850 from adopting rules 00:46:03.850 --> 00:46:06.250 that would provide a greater degree of customer protection. 00:46:06.250 --> 00:46:07.160 That's true. 00:46:07.160 --> 00:46:10.403 And under Piera 39101, 00:46:12.130 --> 00:46:14.870 the Commission will ensure that retail customer protections 00:46:14.870 --> 00:46:17.160 are established that entitled customer to say for liable 00:46:17.160 --> 00:46:19.450 and reasonably priced electricity and protections. 00:46:19.450 --> 00:46:23.320 So, we have brought it already under existing 39101 00:46:23.320 --> 00:46:26.600 and HB 16 itself says that we can go above and beyond 00:46:26.600 --> 00:46:28.820 the wholesale price index plan prohibition. 00:46:28.820 --> 00:46:31.990 And so, based on my experience at OPEC, 00:46:31.990 --> 00:46:33.840 I believe that we should do everything we can 00:46:33.840 --> 00:46:35.250 to protect consumers in the future 00:46:35.250 --> 00:46:38.310 should we have another major storm 00:46:38.310 --> 00:46:40.730 that busts the seams in our retail market, 00:46:40.730 --> 00:46:43.870 and we have consumers that are exposed to costs 00:46:43.870 --> 00:46:48.283 that we can help to close the door on right now today. 00:46:49.237 --> 00:46:50.070 Right, I hear you. 00:46:50.070 --> 00:46:53.520 I'm trying to, at the minimum, 00:46:53.520 --> 00:46:56.240 follow the clear directives of the statute. 00:46:56.240 --> 00:46:57.100 Anything over and above, 00:46:57.100 --> 00:47:00.380 we can absolutely certainly do and should consider it. 00:47:00.380 --> 00:47:02.360 So, I bound that argument. 00:47:02.360 --> 00:47:03.193 Jeremy. 00:47:06.155 --> 00:47:06.988 Oh, boy. 00:47:09.550 --> 00:47:10.810 Not totally the issue 00:47:10.810 --> 00:47:12.800 that I have spent a whole lot of time 00:47:12.800 --> 00:47:14.890 focusing on this week, I apologize. 00:47:14.890 --> 00:47:16.900 No, we've all got a lot going on. 00:47:16.900 --> 00:47:18.050 Yes, ma'am. 00:47:18.050 --> 00:47:19.150 If it's helpful, 00:47:19.150 --> 00:47:23.680 and it may be helpful to those watching and the public too, 00:47:23.680 --> 00:47:26.850 this particular question is focused 00:47:26.850 --> 00:47:31.790 solely on the calculation of the maximum allowed polar price 00:47:31.790 --> 00:47:35.770 and wouldn't affect any general prices in the retail market. 00:47:35.770 --> 00:47:37.790 So, that might be helpful 00:47:38.684 --> 00:47:42.493 as you work through your discussion to keep that in mind. 00:47:43.476 --> 00:47:46.150 And 20% is a significant percentage, 00:47:46.150 --> 00:47:49.970 I mean, that's not a very tight threshold. 00:47:49.970 --> 00:47:53.190 I mean, there's still some flexibility there. 00:47:53.190 --> 00:47:54.943 That's right. It's not 5%. 00:47:56.850 --> 00:47:57.925 Exactly. 00:47:57.925 --> 00:48:00.040 I mean, I just threw that out there as an example. 00:48:00.040 --> 00:48:04.357 I guess the first question is cap, 00:48:09.890 --> 00:48:11.060 Should there be a cap? 00:48:11.060 --> 00:48:14.520 If so, and I think, I mean, I think, yes, 00:48:14.520 --> 00:48:16.160 what should that number be? 00:48:16.160 --> 00:48:18.293 20%, 50%? 00:48:19.350 --> 00:48:22.210 I mean, if prices don't move much in a year, 20% is a lot, 00:48:22.210 --> 00:48:24.859 if they double in a year, 20% is not nearly enough. 00:48:24.859 --> 00:48:26.095 Right. 00:48:26.095 --> 00:48:27.873 And the reps getting, 00:48:29.276 --> 00:48:30.109 are losing money. 00:48:30.109 --> 00:48:33.841 And that's driven primarily by probably gas prices here, 00:48:33.841 --> 00:48:35.040 is that right? 00:48:35.040 --> 00:48:38.960 Now, it's 50% of the fleet that can change. 00:48:38.960 --> 00:48:40.483 Gas prices can go, 00:48:41.910 --> 00:48:43.650 they were a dollar, 50 two years ago. 00:48:43.650 --> 00:48:44.698 That's my point. 00:48:44.698 --> 00:48:45.531 Yeah. 00:48:45.531 --> 00:48:48.890 So, I would rather base the percentage 00:48:48.890 --> 00:48:53.320 on actual submitted stakeholder comments and documentation 00:48:53.320 --> 00:48:54.220 that's in, 00:48:54.220 --> 00:48:56.260 it's not a contested case, but it's in the record. 00:48:56.260 --> 00:48:58.060 So, that's why I would lean towards 20% 00:48:58.060 --> 00:49:00.230 because I'd rather not pick an arbitrary number. 00:49:00.230 --> 00:49:01.063 I'm okay with that. 00:49:01.063 --> 00:49:01.896 Me too. Yeah. 00:49:01.896 --> 00:49:03.580 And knowing that you guys are interested in this, 00:49:03.580 --> 00:49:04.640 I mean, the way we would implement it, 00:49:04.640 --> 00:49:08.250 sort of a lesser of 20% of, 00:49:08.250 --> 00:49:11.440 above the average prices from last year, 00:49:11.440 --> 00:49:13.730 but it would also be capped. 00:49:13.730 --> 00:49:14.650 So, it would just be a cap, 00:49:14.650 --> 00:49:16.290 it wouldn't always go up 20% each year, 00:49:16.290 --> 00:49:17.257 is what I'm trying to say. 00:49:17.257 --> 00:49:20.160 And the average reduces a lot of the volatility. 00:49:20.160 --> 00:49:21.907 Correct. As well. 00:49:21.907 --> 00:49:24.730 And we will go back through the comments 00:49:24.730 --> 00:49:29.730 and ensure that we've fully captured and considered, 00:49:31.940 --> 00:49:34.150 in the draft order, 00:49:34.150 --> 00:49:36.130 all of the comments related to this topic 00:49:36.130 --> 00:49:40.980 so that you may select a number based on that record, 00:49:40.980 --> 00:49:44.750 but our recommendation will come in at 20%. 00:49:44.750 --> 00:49:45.630 Good deal. 00:49:45.630 --> 00:49:46.463 Thank you. 00:49:46.463 --> 00:49:47.640 Next item, Mr. Smeltzer. 00:49:49.248 --> 00:49:52.360 So, another item that we had decided, 00:49:52.360 --> 00:49:54.500 this was the fixed means, fixed conversation, 00:49:54.500 --> 00:49:57.210 it's whether or not ancillary services charges 00:49:57.210 --> 00:50:00.600 are a component of the price for a fixed-rate product. 00:50:00.600 --> 00:50:01.860 And so, the issue there 00:50:01.860 --> 00:50:05.150 is typically if they are under the rule, 00:50:05.150 --> 00:50:09.240 if there are new charges that reps are not aware of, 00:50:09.240 --> 00:50:11.260 they often are allowed to vary prices, 00:50:11.260 --> 00:50:13.420 even in fixed rate contracts based on that, 00:50:13.420 --> 00:50:14.500 I think staff's interpretation 00:50:14.500 --> 00:50:16.500 has always been that ancillary services 00:50:16.500 --> 00:50:18.670 are not one of those things that count as new. 00:50:18.670 --> 00:50:22.010 But I think in a world where we're increasing the amount 00:50:22.010 --> 00:50:23.240 of ancillary service that we purchase, 00:50:23.240 --> 00:50:24.310 and there's also the possibility 00:50:24.310 --> 00:50:26.480 that new ancillary services could be adopted, 00:50:26.480 --> 00:50:28.130 the retail provider community 00:50:28.130 --> 00:50:31.480 argues that they want flexibility to adjust prices 00:50:31.480 --> 00:50:32.750 based on these new charges 00:50:32.750 --> 00:50:34.490 would not have been predicted to them. 00:50:34.490 --> 00:50:36.950 The other side of that argument broadly speaking, 00:50:36.950 --> 00:50:41.110 is that our market design is trying to rest the risk 00:50:41.110 --> 00:50:42.510 in public entities 00:50:42.510 --> 00:50:44.300 and that the retail electric product community 00:50:44.300 --> 00:50:47.070 sort of position a shield against consumers, 00:50:47.070 --> 00:50:48.480 against that risk for consumers. 00:50:48.480 --> 00:50:49.910 And so, I guess the question here, 00:50:49.910 --> 00:50:53.910 is if new ancillary services are adopted or increased, 00:50:53.910 --> 00:50:55.450 we want the risk of that price 00:50:55.450 --> 00:50:58.360 to rest with the end consumers 00:50:58.360 --> 00:51:00.950 or with the retail electric providers. 00:51:00.950 --> 00:51:02.320 Thank you, Mr. Smeltzer again, 00:51:02.320 --> 00:51:04.510 or former OPEC, I'll defer to you to. 00:51:04.510 --> 00:51:07.000 Well, I was going to say that I was gonna defer 00:51:07.000 --> 00:51:08.930 to Chairman Lake and Commissioner McAdams 00:51:08.930 --> 00:51:09.890 to state where they are today 00:51:09.890 --> 00:51:12.090 since they're the ones that introduced this concept. 00:51:12.090 --> 00:51:14.810 And then I'll follow back up and- Sure. 00:51:14.810 --> 00:51:17.060 As I've said, I mean, we've discussed many times, 00:51:17.060 --> 00:51:20.933 fixed means fixed, and as Mr. Smeltzer nicely laid out, 00:51:22.270 --> 00:51:27.120 price risk should lie on the private financial entity, 00:51:27.120 --> 00:51:29.630 not on individual customers and households 00:51:30.660 --> 00:51:33.350 and companies that are better at managing financial risks 00:51:33.350 --> 00:51:35.313 will be rewarded with market share. 00:51:38.090 --> 00:51:40.217 I agree, I agreed the last time we discussed it, 00:51:40.217 --> 00:51:43.623 and I agree now, fixed means fixed. 00:51:44.690 --> 00:51:46.100 Okay. 00:51:46.100 --> 00:51:47.200 I would like to note something 00:51:47.200 --> 00:51:49.670 that I think OPEC filed in their comments 00:51:49.670 --> 00:51:51.920 and I've gone back and reviewed, 00:51:51.920 --> 00:51:54.340 and that is an order that was issued in 2009, 00:51:54.340 --> 00:51:56.323 adopting rule 25475. 00:51:57.270 --> 00:52:01.380 The Commission's response to comments that were filed, 00:52:01.380 --> 00:52:06.380 specifically stated that the Commission clarified basically 00:52:07.390 --> 00:52:08.920 that fixed-rate product 00:52:08.920 --> 00:52:10.940 or fees include fees approved by the Commission 00:52:10.940 --> 00:52:12.270 and charges to load 00:52:12.270 --> 00:52:15.430 such as ERCOT administrative fees and nodal fee 00:52:15.430 --> 00:52:16.970 should it be charged with loads in the future. 00:52:16.970 --> 00:52:19.220 Under that definition of fixed rate product, 00:52:19.220 --> 00:52:22.083 ERCOT fees would not include ancillary services, 00:52:23.210 --> 00:52:26.280 losses, or unaccounted for energy charges for TRE penalties. 00:52:26.280 --> 00:52:30.620 So, the order adopting 25475 that we are replacing, 00:52:30.620 --> 00:52:32.020 that was their position back then, 00:52:32.020 --> 00:52:32.853 that fixed rate product 00:52:32.853 --> 00:52:35.470 did not include ancillary service charges. 00:52:35.470 --> 00:52:38.130 And so, those would not be able 00:52:38.130 --> 00:52:40.160 to patent past through a fixed rate product. 00:52:40.160 --> 00:52:41.410 Right, it's consistent. 00:52:43.450 --> 00:52:45.200 Yes, Commission staff understands, 00:52:45.200 --> 00:52:46.535 this as just providing a clarification 00:52:46.535 --> 00:52:48.480 on what we already interpreted the lot to be, 00:52:48.480 --> 00:52:50.430 but I guess there was enough ambiguity. 00:52:52.250 --> 00:52:54.910 The stakeholders raised questions of him. 00:52:54.910 --> 00:52:56.410 Yes, sir. Yeah. 00:52:56.410 --> 00:52:58.700 Does this affect existing fixed-rate products, 00:52:58.700 --> 00:53:00.123 or is this just perspective? 00:53:01.350 --> 00:53:02.720 Sir, again, I think 00:53:02.720 --> 00:53:05.160 that if that Commission staff's perspective 00:53:05.160 --> 00:53:07.730 is that this is already what our interpretation of the law 00:53:07.730 --> 00:53:08.563 would have been, 00:53:08.563 --> 00:53:09.510 ancillary services are not something 00:53:09.510 --> 00:53:11.790 that reps can vary the price of the contracts based on, 00:53:11.790 --> 00:53:13.029 but this would clarify. 00:53:13.029 --> 00:53:16.850 So, to the extent that we could be wrong about that, 00:53:16.850 --> 00:53:17.720 this clarification 00:53:17.720 --> 00:53:21.660 would only affect contracts moving forward, 00:53:21.660 --> 00:53:24.860 but our interpretation is that it that's already the law now 00:53:24.860 --> 00:53:28.350 with what we would argue if it ever came up in a case. 00:53:28.350 --> 00:53:29.713 And I will say that, 00:53:30.800 --> 00:53:33.950 recognizing the actions that we're taking this summer, 00:53:33.950 --> 00:53:36.340 that I've had conversations with reps myself. 00:53:36.340 --> 00:53:40.490 And the goal here is to try work really hard 00:53:40.490 --> 00:53:41.370 to provide transparency 00:53:41.370 --> 00:53:44.020 in ancillary service costs in the future work with ERCOT 00:53:44.020 --> 00:53:47.513 as they look to approve their ancillary service methodology, 00:53:48.440 --> 00:53:51.240 to ensure that we're providing as much transparency 00:53:51.240 --> 00:53:53.740 going forward on the ancillary services 00:53:53.740 --> 00:53:55.390 that ERCOT is procuring in the future. 00:53:55.390 --> 00:53:57.830 I mean, we are expected to stay in conservative operations 00:53:57.830 --> 00:54:00.100 so that that should provide some transparency 00:54:00.100 --> 00:54:01.700 as to where we're headed. 00:54:01.700 --> 00:54:04.040 ECRS has not been scoped out yet, 00:54:04.040 --> 00:54:09.040 but as we reach the final stages of ECRS go-live, 00:54:10.530 --> 00:54:12.730 making sure that we're providing more transparency 00:54:12.730 --> 00:54:13.640 to the retail market 00:54:13.640 --> 00:54:16.390 so they can adjust and hedge appropriately their costs. 00:54:17.630 --> 00:54:19.470 Yeah, the one other thing that I would cite on this, 00:54:19.470 --> 00:54:24.470 is if ancillary services are not, or are outside, 00:54:25.619 --> 00:54:26.940 or we're making sure 00:54:26.940 --> 00:54:29.570 that they go inside the component of the fixed rate, 00:54:29.570 --> 00:54:31.664 these rates will be adjusted 00:54:31.664 --> 00:54:34.280 at some point in time in the future with a risk premium 00:54:34.280 --> 00:54:37.410 associated for ancillary services that are not included. 00:54:37.410 --> 00:54:39.760 It's ultimately, the consumer is gonna pay this, 00:54:39.760 --> 00:54:42.420 whether it is ancillary services 00:54:42.420 --> 00:54:43.710 outside the fixed-rate contract 00:54:43.710 --> 00:54:45.580 or within the fixed-rate contract. 00:54:45.580 --> 00:54:50.580 And it's my view that the retail providers won't eat this, 00:54:51.110 --> 00:54:53.320 these are market costs that are put on them 00:54:53.320 --> 00:54:55.330 that will ultimately get passed through to the customer, 00:54:55.330 --> 00:54:56.750 whether they do it now 00:54:56.750 --> 00:54:59.010 or with prospective contracts going forward. 00:54:59.010 --> 00:55:02.670 So, my point is, let's not go into this with blinders 00:55:02.670 --> 00:55:05.080 that the reps are gonna eat this cost. 00:55:05.080 --> 00:55:08.420 It's not gonna happen that way, these are system-wide costs, 00:55:08.420 --> 00:55:11.400 ancillary services are system-wide costs 00:55:11.400 --> 00:55:13.360 that go to all consumers. 00:55:13.360 --> 00:55:17.360 Yes, but this does protect individual households 00:55:17.360 --> 00:55:21.730 from extraordinary price spikes at certain moments in time. 00:55:21.730 --> 00:55:23.740 Agreed, which we saw in February. 00:55:23.740 --> 00:55:24.640 Right. Absolutely. 00:55:24.640 --> 00:55:26.950 So, that's the consumer protection, 00:55:26.950 --> 00:55:29.880 I think is so important here. 00:55:29.880 --> 00:55:32.650 And there's a, as you pointed out, 00:55:32.650 --> 00:55:35.900 there's an entire universe of financial markets, 00:55:35.900 --> 00:55:38.073 risk products, options, 00:55:39.520 --> 00:55:42.380 there's an entire universe of products 00:55:42.380 --> 00:55:46.670 to help these retail provider companies mitigate that risk. 00:55:46.670 --> 00:55:47.503 Call New York, 00:55:47.503 --> 00:55:50.060 they've got all sorts of things they'll tell you. 00:55:50.060 --> 00:55:52.170 Individual households don't have that ability, 00:55:52.170 --> 00:55:54.600 and they shouldn't be expected to. 00:55:54.600 --> 00:55:57.820 So, yes, some element of this will be passed on, 00:55:57.820 --> 00:56:01.920 but the benefit to the consumer is eliminating the risk 00:56:01.920 --> 00:56:06.920 of discrete extraordinary financial costs, 00:56:07.450 --> 00:56:08.673 which is important. 00:56:09.550 --> 00:56:12.323 All right, so, we got that issue addressed. 00:56:13.653 --> 00:56:15.380 Do you have everything you need on that? 00:56:15.380 --> 00:56:20.320 Yes, so, the answer to that is, yes, it should include, 00:56:20.320 --> 00:56:22.030 fixed is fixed. Fixed is fixed. 00:56:22.030 --> 00:56:23.610 Okay. Yes. 00:56:23.610 --> 00:56:24.620 The next one is, 00:56:24.620 --> 00:56:28.850 HB 16 specifically prohibited wholesale index products 00:56:28.850 --> 00:56:31.230 for residential and small commercial customers 00:56:31.230 --> 00:56:32.580 that allow these products to move forward 00:56:32.580 --> 00:56:34.940 for large commercial and industrial customers 00:56:34.940 --> 00:56:36.590 with the acknowledgement of risk. 00:56:37.780 --> 00:56:39.890 Last time, we were asked to explore 00:56:39.890 --> 00:56:41.900 additional customer protections, 00:56:41.900 --> 00:56:42.770 one that we came up with 00:56:42.770 --> 00:56:47.770 was maybe we would apply this acknowledgment of risk format 00:56:47.850 --> 00:56:49.520 to residential small groups from customers 00:56:49.520 --> 00:56:51.060 with a number of products, 00:56:51.060 --> 00:56:53.870 like any index product, for instance. 00:56:53.870 --> 00:56:55.010 But in the comments, 00:56:55.010 --> 00:56:56.960 and I think it's one of the briefing questions, 00:56:56.960 --> 00:57:00.130 it was suggested that perhaps these index products 00:57:00.130 --> 00:57:01.040 are across the board, 00:57:01.040 --> 00:57:04.940 more risky than customers should be exposed to. 00:57:04.940 --> 00:57:06.720 So, there was the proposal. 00:57:06.720 --> 00:57:09.730 So, our proposed PFP did not include this, 00:57:09.730 --> 00:57:13.520 but one idea is that that just index products 00:57:13.520 --> 00:57:14.687 should not be a part of the residential 00:57:14.687 --> 00:57:15.990 and small commercial market. 00:57:15.990 --> 00:57:19.130 And so, that is one that we did not necessarily receive 00:57:19.130 --> 00:57:21.840 far from direction from you guys on one way or the other, 00:57:21.840 --> 00:57:24.230 and one that I would not fame 00:57:24.230 --> 00:57:26.131 to guess where you guys were on on it, 00:57:26.131 --> 00:57:27.590 if I was writing an order. 00:57:27.590 --> 00:57:28.850 All right, thank you, David. 00:57:28.850 --> 00:57:31.920 And I believe a lot of the comments that were filed 00:57:31.920 --> 00:57:34.460 expressed concern about prohibiting index products, 00:57:34.460 --> 00:57:36.570 because many times, 00:57:36.570 --> 00:57:39.900 a time of use products are often considered index products. 00:57:39.900 --> 00:57:41.930 I think there's two ways of looking at this issue, 00:57:41.930 --> 00:57:43.880 one is we add in a rule 00:57:43.880 --> 00:57:46.480 that time of use products are still allowed 00:57:48.240 --> 00:57:50.363 and index products are not. 00:57:52.084 --> 00:57:54.490 But my concern is that I don't think 00:57:54.490 --> 00:57:57.053 there are very many other types of index products 00:57:57.053 --> 00:57:59.330 outside of time of use products out there, 00:57:59.330 --> 00:58:01.060 I haven't heard of any really. 00:58:01.060 --> 00:58:05.110 And Connie, please elaborate if you. 00:58:05.110 --> 00:58:07.840 No, that's correct, I don't believe it's widely used, 00:58:07.840 --> 00:58:09.410 it's mostly used for time of use, 00:58:09.410 --> 00:58:13.010 which can arguably fall 00:58:13.010 --> 00:58:14.940 into either the fixed or the variable, 00:58:14.940 --> 00:58:16.550 depending on how it's structured, 00:58:16.550 --> 00:58:18.943 it does not have to be an index product. 00:58:20.030 --> 00:58:21.412 So, I would not wanna get, 00:58:21.412 --> 00:58:24.150 I would not wanna prohibit time of use products. 00:58:24.150 --> 00:58:28.540 And I think in our role, if we agree, 00:58:28.540 --> 00:58:30.830 we could insert some language in there 00:58:30.830 --> 00:58:32.780 that time of use products are still allowed. 00:58:32.780 --> 00:58:34.920 We still wanna have innovation, 00:58:34.920 --> 00:58:38.343 we still wanna have options for consumers, 00:58:39.300 --> 00:58:43.320 but knowing what we saw with the wholesale price index plans 00:58:43.320 --> 00:58:47.330 and knowing that even if an EFL has details in it 00:58:47.330 --> 00:58:52.090 or an AOR that states how it works, 00:58:52.090 --> 00:58:54.830 many residential and small commercial consumers 00:58:54.830 --> 00:58:56.260 are still not gonna understand 00:58:56.260 --> 00:58:57.772 what they're signing themselves up for. 00:58:57.772 --> 00:58:58.605 Right. 00:58:58.605 --> 00:59:03.280 And I wanna close the door on it, is my preference, 00:59:04.920 --> 00:59:07.970 but I don't wanna close the door in time of use products, 00:59:07.970 --> 00:59:11.760 but I'd be happy to hear your thoughts on the issue. 00:59:11.760 --> 00:59:15.690 Yeah, I know we'll hear from our guests in a second, 00:59:15.690 --> 00:59:19.170 I think, yes, index should not be allowed 00:59:19.170 --> 00:59:22.313 for small residential, small commercial. 00:59:24.470 --> 00:59:26.870 Index can be anything, right? 00:59:26.870 --> 00:59:30.763 It can be a weighted average of Bitcoin in LIBOR, right? 00:59:32.830 --> 00:59:37.060 But we do wanna accommodate that, the innovative product. 00:59:37.060 --> 00:59:39.710 So, I would even expand the exception, 00:59:39.710 --> 00:59:41.610 it's an exception for time of use, 00:59:41.610 --> 00:59:46.610 to say any product based on your time calendar, 00:59:48.670 --> 00:59:51.380 or any other finite metric, right? 00:59:51.380 --> 00:59:53.850 Like you can't put more than 24 hours in the day, 00:59:53.850 --> 00:59:58.850 but Bitcoin can go, who knows where. 00:59:59.151 --> 01:00:03.360 So, expand, make sure we accommodate future products 01:00:03.360 --> 01:00:05.420 that nobody's thought of yet. 01:00:05.420 --> 01:00:06.600 Sure. For future retailers. 01:00:06.600 --> 01:00:08.870 As long as it's in a fixed universe 01:00:08.870 --> 01:00:10.550 or fixed some sort of fixed battery, 01:00:10.550 --> 01:00:12.210 I don't know what the right language for that is, 01:00:12.210 --> 01:00:15.610 but I wouldn't limit the exception to time of use, 01:00:15.610 --> 01:00:17.820 I would open it up, okay. 01:00:17.820 --> 01:00:20.130 Liberty, time of use in some language, 01:00:20.130 --> 01:00:21.810 but we gotta be careful too, 01:00:21.810 --> 01:00:23.440 'cause we can open the door to something 01:00:23.440 --> 01:00:24.940 by just some general language, 01:00:25.810 --> 01:00:28.147 but I'm willing to have that discussion with- 01:00:28.147 --> 01:00:30.320 We can ask them to think about it. 01:00:30.320 --> 01:00:34.810 Yeah, so, again, my initial comments on flexibility, 01:00:34.810 --> 01:00:39.810 I just wanna make sure ERCOT has those innovative tools 01:00:40.020 --> 01:00:43.240 that are coming online, time of use, 01:00:43.240 --> 01:00:45.120 great examples for small commercial, 01:00:45.120 --> 01:00:48.380 those freezers, and stuff like that, if they can sign up, 01:00:48.380 --> 01:00:52.820 we can help manage these reliability constraints 01:00:52.820 --> 01:00:53.900 in the near term. 01:00:53.900 --> 01:00:55.290 And I just don't, 01:00:55.290 --> 01:00:56.920 I wanna make sure we get that language right. 01:00:56.920 --> 01:00:58.400 And I concur with you, Mr. Chairman, 01:00:58.400 --> 01:01:00.460 we wanna make sure we leave it 01:01:01.720 --> 01:01:03.730 broad enough to envision the future 01:01:03.730 --> 01:01:05.260 of where the market's headed. 01:01:05.260 --> 01:01:06.310 Stuff that we have thought of yet. 01:01:06.310 --> 01:01:07.351 Yeah. 01:01:07.351 --> 01:01:08.325 So, what I'm hearing, 01:01:08.325 --> 01:01:10.220 is there's a sort of a line in the sand 01:01:10.220 --> 01:01:13.520 and indexing to re real-time prices 01:01:13.520 --> 01:01:15.400 and indexing to something like the NYMEX 01:01:15.400 --> 01:01:17.470 is probably on one side of the line, 01:01:17.470 --> 01:01:21.750 whereas time of use prices and other things like that 01:01:21.750 --> 01:01:24.590 that are more structured to have less spiky risks 01:01:24.590 --> 01:01:26.087 associated with them around the other side of the line, 01:01:26.087 --> 01:01:28.150 and you want us to try and find- 01:01:28.150 --> 01:01:29.173 More transparency, 01:01:30.060 --> 01:01:33.960 more understand that are better understood by the consumers. 01:01:33.960 --> 01:01:34.923 Okay, and so. 01:01:37.050 --> 01:01:39.100 Volatility based, not like historically, 01:01:39.100 --> 01:01:42.430 it's been just fine, I'd fix it on a quantity, 01:01:42.430 --> 01:01:43.900 like I fixed universe, 01:01:43.900 --> 01:01:45.190 I don't know the right language, right? 01:01:45.190 --> 01:01:48.480 Like, I mean, past performance of health and wellness, 01:01:48.480 --> 01:01:50.250 like turkey has extraordinary performance 01:01:50.250 --> 01:01:55.250 until Thanksgiving, so, we wanna stay away from that. 01:01:55.420 --> 01:01:57.720 But as long as- Is in the NYMEX category. 01:01:58.800 --> 01:02:01.503 But like time of use is, or time of day is, 01:02:02.365 --> 01:02:03.510 it was 24 hours in a day. 01:02:03.510 --> 01:02:06.723 We know that's a fixed universe that can't, 01:02:08.703 --> 01:02:11.065 that has no volatility, right? 01:02:11.065 --> 01:02:12.520 It can't have volatility. 01:02:12.520 --> 01:02:16.430 And Commissioner, I think we can work on rural language 01:02:16.430 --> 01:02:18.130 to effectuate this 01:02:18.130 --> 01:02:23.130 and also the concept between fixed and variable. 01:02:24.830 --> 01:02:27.113 So, for example, 01:02:28.290 --> 01:02:33.290 a fixed price is one that for certain, 01:02:33.350 --> 01:02:37.670 that you'll be paying for the next X number of months 01:02:37.670 --> 01:02:41.110 and that price during the course of a day 01:02:41.110 --> 01:02:44.300 may be different in one hour than the next. 01:02:44.300 --> 01:02:47.590 But you know, ahead of time that in the morning, 01:02:47.590 --> 01:02:52.590 you're paying 6 cents and at peak you're paying 8 cents, 01:02:53.620 --> 01:02:54.730 something like that, 01:02:54.730 --> 01:02:58.760 that is a fixed product, it's also time of use. 01:02:58.760 --> 01:03:02.163 So, I think we can work with language there. 01:03:03.840 --> 01:03:06.293 Full fight staff and come up with something appropriate 01:03:06.293 --> 01:03:07.860 that protects the customer 01:03:07.860 --> 01:03:10.650 while also allowing innovative products 01:03:10.650 --> 01:03:12.457 and future innovative products. 01:03:12.457 --> 01:03:13.910 And variable, 01:03:13.910 --> 01:03:17.100 having that variable month-to-month product out there 01:03:17.100 --> 01:03:18.880 available in our definitions 01:03:18.880 --> 01:03:21.443 covers a wide range of innovative products. 01:03:22.700 --> 01:03:25.014 I'm suggesting we leave turkeys out of it 01:03:25.014 --> 01:03:26.180 in the next iteration, please. 01:03:26.180 --> 01:03:27.430 Yes. Yes, sir. 01:03:28.939 --> 01:03:29.772 Thank you. 01:03:29.772 --> 01:03:30.605 Yes ma'am. 01:03:30.605 --> 01:03:33.490 Carrie Collier-Brown with the lions for retail markets 01:03:33.490 --> 01:03:36.573 just wanted to make a couple of clarifications. 01:03:37.764 --> 01:03:40.920 So, the rules have three different types of products, 01:03:40.920 --> 01:03:44.470 fixed variable or indexed. 01:03:44.470 --> 01:03:48.170 And to the time-of-use plans, 01:03:48.170 --> 01:03:52.420 those could be fit in any of those three categories 01:03:53.350 --> 01:03:54.610 depending on how it's going. 01:03:54.610 --> 01:03:56.830 You know exactly what your price is gonna be 01:03:56.830 --> 01:04:01.830 at certain times of the day, that would be fixed. 01:04:02.180 --> 01:04:05.020 The different times of the day could be variable, 01:04:05.020 --> 01:04:08.410 or it could be indexed to something. 01:04:08.410 --> 01:04:11.823 And on index products, 01:04:12.940 --> 01:04:15.410 my understanding, is that generally, 01:04:15.410 --> 01:04:18.930 the index products offered to residential customers 01:04:18.930 --> 01:04:20.810 are only time-of-use-type products, 01:04:20.810 --> 01:04:24.440 but what their index to could be different things. 01:04:24.440 --> 01:04:27.570 And I think my understanding from our members- 01:04:27.570 --> 01:04:28.637 Example. 01:04:28.637 --> 01:04:30.070 Is the most common, 01:04:30.070 --> 01:04:33.750 is the products that are index to the NYMEX 01:04:33.750 --> 01:04:35.470 so they would use the closing price 01:04:35.470 --> 01:04:38.630 of the monthly NYMEX Natural Gas Futures Contract. 01:04:38.630 --> 01:04:41.150 And this is a couple of months outdated 01:04:41.150 --> 01:04:42.800 when I looked at this last time. 01:04:42.800 --> 01:04:44.020 But for 2021, 01:04:44.020 --> 01:04:48.443 that value range from between $2 and 50 cents to $4. 01:04:49.430 --> 01:04:52.220 So, it's a type of indexed product 01:04:52.220 --> 01:04:55.000 that is not particularly volatile 01:04:55.000 --> 01:04:57.210 and does not have the same issues that were identified 01:04:57.210 --> 01:04:58.380 by the legislatures, 01:04:58.380 --> 01:05:01.920 the reason why they took, pretty bold action 01:05:01.920 --> 01:05:04.270 to ban an entire product for certain customers. 01:05:06.400 --> 01:05:07.850 Thank you. 01:05:07.850 --> 01:05:09.696 I think Connie's point, 01:05:09.696 --> 01:05:13.550 it's the nail on the head by saying that the fixed part 01:05:13.550 --> 01:05:17.100 is the financial component, the cost. 01:05:17.100 --> 01:05:20.230 When each of those finite costs are applied 01:05:21.090 --> 01:05:23.290 is that can be variable, 01:05:23.290 --> 01:05:25.483 but the amount of money the customer pays, 01:05:26.590 --> 01:05:28.340 I think we don't want that to vary. 01:05:30.550 --> 01:05:35.550 And that's the bottom line, I'm sure the staff can, 01:05:35.693 --> 01:05:36.999 I know 'cause that makes sense. 01:05:36.999 --> 01:05:38.350 Okay, I think we understand you. 01:05:38.350 --> 01:05:39.870 My goal is to have language 01:05:39.870 --> 01:05:43.940 that does not get in the way of time of use products. 01:05:43.940 --> 01:05:47.810 I know your example, Carrie is NYMEX, I'm not sure that, 01:05:47.810 --> 01:05:49.490 I don't know how much enrollment is out there 01:05:49.490 --> 01:05:50.323 on that product. 01:05:50.323 --> 01:05:51.920 I'm not sure that we're really causing any harm 01:05:51.920 --> 01:05:53.410 by batting something like that, 01:05:53.410 --> 01:05:55.650 but I don't wanna cause harm on his time of use product. 01:05:55.650 --> 01:05:57.490 So, we could set it up in a way 01:05:57.490 --> 01:05:59.966 where there's just through the EFL, 01:05:59.966 --> 01:06:02.470 through customer information 01:06:02.470 --> 01:06:04.970 that is transparent of how those are used. 01:06:04.970 --> 01:06:07.420 I'm comfortable with that, I don't wanna stop innovation, 01:06:07.420 --> 01:06:09.840 I don't wanna limit options for customers, 01:06:09.840 --> 01:06:13.293 but I don't wanna have obscure indexes in the market. 01:06:14.590 --> 01:06:16.920 And we totally understand that and agree with that. 01:06:16.920 --> 01:06:21.920 The rules already provide, the EFL provide disclosures 01:06:22.280 --> 01:06:25.200 even on the index time of use products 01:06:25.200 --> 01:06:29.220 and the are requiring the reps to provide information 01:06:29.220 --> 01:06:30.053 say on their website 01:06:30.053 --> 01:06:31.830 where they can see exactly what that's going to be 01:06:31.830 --> 01:06:34.773 based on that for that index. 01:06:36.369 --> 01:06:38.970 I think the timing can be variable, the price can't be. 01:06:38.970 --> 01:06:40.860 And the concern we're trying to address today, 01:06:40.860 --> 01:06:43.220 is that natural gas in the U.K. 01:06:43.220 --> 01:06:46.810 used to be $2 to $4 pretty regularly, now it's $40. 01:06:46.810 --> 01:06:48.360 Understood. Those things change. 01:06:48.360 --> 01:06:50.993 And that's what, is that pesky turkey, Jimmy? 01:06:52.750 --> 01:06:55.830 So, I think that's what we're protecting against. 01:06:55.830 --> 01:06:57.640 So, the second piece to that issue, 01:06:57.640 --> 01:07:00.580 is so, how the issue of whether or not 01:07:00.580 --> 01:07:03.010 we wanna have index products in the market, 01:07:03.010 --> 01:07:04.120 I think the second piece 01:07:04.120 --> 01:07:06.960 is whether we still wanna go without an AOR to it, 01:07:06.960 --> 01:07:09.760 is that bear, or is it either or? 01:07:09.760 --> 01:07:10.593 If we don't. 01:07:10.593 --> 01:07:12.001 Yeah, if we don't have the products in the market, 01:07:12.001 --> 01:07:14.880 then we would need an acknowledgement of risk. 01:07:14.880 --> 01:07:17.260 But I think that that's sort of your, 01:07:17.260 --> 01:07:20.040 I would suggest that you retain the acknowledgement of risk 01:07:20.040 --> 01:07:22.190 if you are going to continue to allow them. 01:07:23.736 --> 01:07:24.830 So, yeah. 01:07:24.830 --> 01:07:27.860 But it is, sorry, isn't it a question of semantics though? 01:07:27.860 --> 01:07:30.797 I mean, as long as we iron out the details on time abuse 01:07:30.797 --> 01:07:35.797 and those allowable flexible plans, you still need an AOR. 01:07:36.030 --> 01:07:37.260 I mean, I don't wanna Tucker Carlson 01:07:37.260 --> 01:07:39.850 talking about people dialing down their thermostat again, 01:07:39.850 --> 01:07:40.900 without their knowledge, 01:07:40.900 --> 01:07:43.123 they need to know what they're signing up for all that. 01:07:43.123 --> 01:07:46.023 Don't say that. I know, but he did. 01:07:47.040 --> 01:07:49.300 The reps are required to provide. 01:07:50.330 --> 01:07:54.960 Yes, Commissioner Cobos, the retail providers 01:07:54.960 --> 01:07:59.370 provide sort of three documents to every enrolling customer. 01:07:59.370 --> 01:08:00.850 You get an electricity facts label, 01:08:00.850 --> 01:08:03.030 which is supposed to be the apples to apples, 01:08:03.030 --> 01:08:07.190 nutritional label idea of the most important contract terms, 01:08:07.190 --> 01:08:10.500 the actual contract, the terms of service, 01:08:10.500 --> 01:08:11.810 and then your rights as a customer, 01:08:11.810 --> 01:08:15.440 which is a summary of the customer protection rules. 01:08:15.440 --> 01:08:18.500 The EFL is the thing that we've all, 01:08:18.500 --> 01:08:20.300 the Commissioner has always encouraged customers 01:08:20.300 --> 01:08:22.800 to use to compare plans. 01:08:22.800 --> 01:08:25.110 And when they're shopping on power to choose website, 01:08:25.110 --> 01:08:27.250 that's the thing that they can bring up in a PDF 01:08:27.250 --> 01:08:28.860 and compare them side by side, 01:08:28.860 --> 01:08:30.440 and that's where the disclosures are. 01:08:30.440 --> 01:08:35.100 So, should you retain some ability 01:08:35.100 --> 01:08:37.610 for reps to offer indexed products 01:08:37.610 --> 01:08:40.173 if it's time of user or however you wanna do that, 01:08:40.173 --> 01:08:43.730 and you want to provide customers and acknowledgment risk. 01:08:43.730 --> 01:08:46.900 We suggest that a place that makes sense, 01:08:46.900 --> 01:08:51.850 is to put that language in the electricity facts label, 01:08:51.850 --> 01:08:53.300 because that's the thing customers see 01:08:53.300 --> 01:08:54.865 when they're shopping. 01:08:54.865 --> 01:08:56.740 And the other thing I'd point out, 01:08:56.740 --> 01:09:00.180 is that's the rule that's open in this particular project, 01:09:00.180 --> 01:09:03.353 is the disclosure rule 25.475. 01:09:04.580 --> 01:09:06.460 I think that there've been some other suggestions 01:09:06.460 --> 01:09:09.290 to put in as part of the enrollment process, 01:09:09.290 --> 01:09:13.810 but that rule is 25.474, and it's really detailed 01:09:13.810 --> 01:09:18.120 about exactly what the reps have to get consent for 01:09:18.120 --> 01:09:21.310 and provide acknowledgement for in each type of enrollment, 01:09:21.310 --> 01:09:24.110 whether it's door to door, or over the phone, 01:09:24.110 --> 01:09:25.393 voice recordings, 01:09:26.350 --> 01:09:28.980 electronic, where they'd have to actually click something. 01:09:28.980 --> 01:09:30.870 If that's something that you wanna do, 01:09:30.870 --> 01:09:33.420 my understanding, I mean we'd have to work with staff, 01:09:33.420 --> 01:09:35.770 but that's not actually in this rulemaking, 01:09:35.770 --> 01:09:39.150 but you could require the disclosure in the EFL, 01:09:39.150 --> 01:09:40.860 which is in this rule-making. 01:09:40.860 --> 01:09:42.960 Sure, and I think for fixed means fixed, 01:09:42.960 --> 01:09:44.880 we don't need to worry about disclosure 01:09:44.880 --> 01:09:46.205 for the price component. 01:09:46.205 --> 01:09:47.038 Right. 01:09:47.038 --> 01:09:50.430 If there can be variability on time as a metric, 01:09:50.430 --> 01:09:53.390 volume, I suspect their play plans, 01:09:53.390 --> 01:09:56.470 or it will be plans where you price varies 01:09:56.470 --> 01:09:58.050 by how much you've used, 01:09:58.050 --> 01:10:01.700 that's something that can that's, 01:10:01.700 --> 01:10:05.140 those are the metrics or the variables 01:10:05.140 --> 01:10:08.860 that we want to continue to allow to be adjusted 01:10:08.860 --> 01:10:10.920 by individual companies. 01:10:10.920 --> 01:10:13.110 Like we would want an acknowledgement of risk 01:10:13.110 --> 01:10:15.370 on those variability. 01:10:15.370 --> 01:10:16.760 And I think it's covered, 01:10:16.760 --> 01:10:19.560 but also remember we heard testimony. 01:10:19.560 --> 01:10:21.550 People are fine at two hours 01:10:21.550 --> 01:10:23.410 when they get throttled for two hours, 01:10:23.410 --> 01:10:27.370 it's when they get throttled for 10 hours on time of use 01:10:27.370 --> 01:10:31.180 or where the pricing scheme or the usage scheme 01:10:31.180 --> 01:10:33.000 is oriented to them. 01:10:33.000 --> 01:10:35.720 They need to know what they're signing up for. 01:10:35.720 --> 01:10:36.590 I agree with your point. 01:10:36.590 --> 01:10:37.970 I think for a fixed rate product, 01:10:37.970 --> 01:10:40.460 you don't need that extra language in the EFL, 01:10:40.460 --> 01:10:41.400 that's straightforward. 01:10:41.400 --> 01:10:43.370 I think even for a variable, 01:10:43.370 --> 01:10:45.550 regular variable rate product it might make sense. 01:10:45.550 --> 01:10:46.920 I think EFL will have some language 01:10:46.920 --> 01:10:48.220 on how the price can vary. 01:10:49.930 --> 01:10:52.430 And then for time of use, 01:10:52.430 --> 01:10:54.940 having maybe some additional information 01:10:54.940 --> 01:10:58.467 to explain how the time of use product, 01:10:58.467 --> 01:11:00.030 and some kind of acknowledgement 01:11:00.030 --> 01:11:02.343 of risk language in the EFL, 01:11:02.343 --> 01:11:05.263 I think I'd be comfortable with that. 01:11:06.550 --> 01:11:08.220 And I think as we designed Commissioners, 01:11:08.220 --> 01:11:10.120 the sort of how to thread the needles 01:11:10.120 --> 01:11:12.390 we discussed it on the different types of products, 01:11:12.390 --> 01:11:13.223 I think we can try 01:11:13.223 --> 01:11:16.350 and come up with a coherent proposal as well 01:11:16.350 --> 01:11:18.960 on what additional language might be in the EFL. 01:11:18.960 --> 01:11:20.480 I think what would be most useful for staff, 01:11:20.480 --> 01:11:22.070 is if you think there are occasions 01:11:22.070 --> 01:11:23.330 when we would want the customer 01:11:23.330 --> 01:11:27.080 to take a sort of discreet affirmative action 01:11:27.080 --> 01:11:27.913 to acknowledge it. 01:11:27.913 --> 01:11:31.030 So, you can put additional texts in EFL 01:11:31.030 --> 01:11:32.510 or in terms of service document. 01:11:32.510 --> 01:11:34.560 Or for instance, with the large commercial customers, 01:11:34.560 --> 01:11:35.570 the legislature made it clear 01:11:35.570 --> 01:11:37.930 that they had to sign an acknowledgement of risk 01:11:37.930 --> 01:11:38.810 as a separate statement. 01:11:38.810 --> 01:11:40.600 And so, for some of these products, 01:11:40.600 --> 01:11:41.550 do we like the idea of the customer 01:11:41.550 --> 01:11:43.870 would have to proactively acknowledge the risk 01:11:43.870 --> 01:11:46.800 as suggested by the name acknowledgement of risk 01:11:46.800 --> 01:11:48.610 with a signature or digital stamp 01:11:48.610 --> 01:11:50.860 or affirmation on a phone call. 01:11:50.860 --> 01:11:52.510 So, that's sort of the guidance that we need, 01:11:52.510 --> 01:11:54.350 whether or not you think just a written disclosure is enough 01:11:54.350 --> 01:11:57.770 versus a proactive action on half of behalf of the customer. 01:11:57.770 --> 01:12:01.010 Okay, so, I'm hearing that you would prefer 01:12:01.010 --> 01:12:03.093 a separate acknowledgement of risk. 01:12:04.140 --> 01:12:05.180 Or a proactive one, 01:12:05.180 --> 01:12:08.507 we can't just scroll through the texts, the final print. 01:12:08.507 --> 01:12:11.224 And even the box checking, you know what I mean? 01:12:11.224 --> 01:12:12.960 Proactively, you say, 01:12:12.960 --> 01:12:16.470 yes, I acknowledged the price of my power changes. 01:12:16.470 --> 01:12:17.593 Okay. 01:12:17.593 --> 01:12:18.426 Kind of like when you're going 01:12:18.426 --> 01:12:19.963 through that rental agreement and stuff like that. 01:12:19.963 --> 01:12:21.247 Okay. 01:12:21.247 --> 01:12:23.900 Right, and it's a pain in the tail, but. 01:12:23.900 --> 01:12:25.950 Okay, so, not just baking 01:12:25.950 --> 01:12:28.710 in the inner energy electricity facts label 01:12:28.710 --> 01:12:30.740 would be sufficient, you'd want an actual- 01:12:30.740 --> 01:12:32.170 Proactive affirmation. 01:12:32.170 --> 01:12:34.340 That makes sense, that makes sense. 01:12:34.340 --> 01:12:36.210 I was trying to strike a balance here, 01:12:36.210 --> 01:12:38.930 but I think if obviously going a step further 01:12:38.930 --> 01:12:40.530 to ensure, even with time of use, 01:12:40.530 --> 01:12:43.520 what you might be getting yourself into would be prudent. 01:12:44.487 --> 01:12:45.940 Yeah, and to be clear, 01:12:45.940 --> 01:12:48.363 we've moved on to question four of the memo. 01:12:49.620 --> 01:12:50.520 I saw the light. 01:12:54.270 --> 01:12:56.890 So, anything else you need from us, Mr. Smeltzer? 01:12:56.890 --> 01:13:00.260 No, sorry, I think that does it on this, thank you. 01:13:00.260 --> 01:13:02.650 I think your third question 01:13:02.650 --> 01:13:06.010 asked about whether or not ancillary service charges 01:13:06.010 --> 01:13:09.513 could be passed through to residential and small commercial, 01:13:10.560 --> 01:13:12.670 that piece I think we might've already answered, 01:13:12.670 --> 01:13:13.503 is that correct? 01:13:13.503 --> 01:13:17.350 I believe the question is if, 01:13:17.350 --> 01:13:20.240 so, we've we got fixed is fixed, 01:13:20.240 --> 01:13:21.870 that would mean any product 01:13:21.870 --> 01:13:24.470 that had an ancillary services passed through 01:13:24.470 --> 01:13:26.610 would be variable. 01:13:26.610 --> 01:13:29.440 And in that case, for a variable product 01:13:29.440 --> 01:13:31.570 with ancillary services passed through, 01:13:31.570 --> 01:13:34.103 would you require the acknowledgement of risk? 01:13:35.160 --> 01:13:36.410 With the crisis to the answer, 01:13:36.410 --> 01:13:37.860 your service is not variable, 01:13:40.550 --> 01:13:43.183 just the time or the quantity is variable. 01:13:45.000 --> 01:13:47.410 This is a, okay, so I think what Connie's saying, 01:13:47.410 --> 01:13:49.310 it's a regular variable rate plan, 01:13:49.310 --> 01:13:52.850 and not a time of use necessarily, not a fixed-rate product, 01:13:52.850 --> 01:13:55.650 but if a residential small commercial consumer 01:13:55.650 --> 01:13:58.750 signed up for a variable rate plan, could the rep 01:13:58.750 --> 01:14:02.290 pass through ancillary service charges to them? 01:14:02.290 --> 01:14:04.540 No, because doesn't that make it an index plan 01:14:04.540 --> 01:14:05.640 when you shoot in your- 01:14:05.640 --> 01:14:06.770 Verbal residential ranch. 01:14:06.770 --> 01:14:07.603 Yeah. 01:14:10.000 --> 01:14:11.393 What are we answering here? 01:14:12.470 --> 01:14:17.470 So, conceivably, a rep could design a plan 01:14:19.760 --> 01:14:21.350 and bill it as variable, 01:14:21.350 --> 01:14:23.260 because it's a month-to-month plan 01:14:23.260 --> 01:14:25.750 and the price changes month to month. 01:14:25.750 --> 01:14:28.470 And the basis of that price change 01:14:28.470 --> 01:14:32.373 would be ancillary services. 01:14:36.518 --> 01:14:38.240 So, yeah, so there's three types of products, right? 01:14:38.240 --> 01:14:39.500 There's the fixed-rate product, 01:14:39.500 --> 01:14:43.160 there's a regular variable rate product 01:14:43.160 --> 01:14:45.970 that's been in the market, that's been month a month, right? 01:14:45.970 --> 01:14:47.793 And then now we've sort of, 01:14:49.250 --> 01:14:52.370 what I'm hearing is eliminated index products, 01:14:52.370 --> 01:14:54.120 but created sort of a separate category 01:14:54.120 --> 01:14:56.640 for time-of-use products. 01:14:56.640 --> 01:14:58.513 And so, I think what staff is asking, 01:14:59.651 --> 01:15:02.380 is that regular variable rate product, 01:15:02.380 --> 01:15:04.910 if you're a small commercial consumer 01:15:04.910 --> 01:15:08.050 or a residential consumer kind of rep pass 01:15:08.050 --> 01:15:09.620 through those ancillary service charges, 01:15:09.620 --> 01:15:12.310 through those regular variable rate plans. 01:15:12.310 --> 01:15:14.050 And I think with a variable rate plan, 01:15:14.050 --> 01:15:15.680 usually, they can do whatever they want with it 01:15:15.680 --> 01:15:16.970 on a month to month. 01:15:16.970 --> 01:15:18.750 And so, this question framed in the way 01:15:18.750 --> 01:15:19.930 that a trim made more sense 01:15:19.930 --> 01:15:23.738 when we were still allowing all the index price plans. 01:15:23.738 --> 01:15:24.571 But we're not. 01:15:24.571 --> 01:15:25.404 But we're not, 01:15:25.404 --> 01:15:27.840 but they're still with the variable rate plan, 01:15:27.840 --> 01:15:29.220 with the reps. 01:15:29.220 --> 01:15:30.200 Unlike a fixed rate plan, 01:15:30.200 --> 01:15:31.500 a variable rate plan plan has the escape patch 01:15:31.500 --> 01:15:32.333 where it's month to month 01:15:32.333 --> 01:15:33.930 and the customer can get out if they want to, 01:15:33.930 --> 01:15:35.840 'cause they have to resign each month. 01:15:35.840 --> 01:15:38.890 But it's whether or not for a type of plan like that, 01:15:38.890 --> 01:15:41.380 do we still want this acknowledgement of Fritz concept 01:15:41.380 --> 01:15:43.360 involved for residential class? 01:15:43.360 --> 01:15:46.010 Great, I think even based on my experience at OPEC, 01:15:47.864 --> 01:15:50.010 the residential consumers have no idea 01:15:50.010 --> 01:15:52.340 what ancillary service charges are. I mean, they just won't, 01:15:52.340 --> 01:15:54.493 even with an acknowledgement of risk. 01:15:56.750 --> 01:15:58.980 Because of the fact that a lot of consumers 01:15:58.980 --> 01:16:02.430 were getting very high electricity bills, 01:16:02.430 --> 01:16:05.833 they were calling us to ensure that their high bill, 01:16:05.833 --> 01:16:09.060 that it include ancillary services in there 01:16:09.060 --> 01:16:10.320 and trying to understand 01:16:10.320 --> 01:16:12.413 what ancillary service charges were. 01:16:14.640 --> 01:16:17.770 Our primary experience during the winter storm, 01:16:17.770 --> 01:16:19.980 was the pastor of ancillary service charges 01:16:19.980 --> 01:16:22.523 to larger commercial consumers. 01:16:24.460 --> 01:16:27.180 I would not allow ancillary service charges 01:16:27.180 --> 01:16:28.347 to be passed through to residential 01:16:28.347 --> 01:16:30.963 and small commercial consumers even with an AOR. 01:16:31.860 --> 01:16:33.560 Agreed. Agreed. 01:16:33.560 --> 01:16:34.710 Thank you. 01:16:34.710 --> 01:16:37.050 Yeah, Commissioner, just for clarification, 01:16:37.050 --> 01:16:39.300 maybe one way to think about it how it helps me, 01:16:39.300 --> 01:16:42.240 is the difference between variable and indexed, 01:16:42.240 --> 01:16:47.240 is that variable has a set rate for that month. 01:16:47.250 --> 01:16:48.450 That rate could change 01:16:48.450 --> 01:16:52.680 based on whatever the criteria is 01:16:52.680 --> 01:16:55.330 that the customer agreed to for the next month. 01:16:55.330 --> 01:16:57.420 So, the month to month, it's like a month to month, 01:16:57.420 --> 01:17:00.973 but what your rate's going to be for each upcoming month. 01:17:02.110 --> 01:17:05.130 Index has some kind of formula in it 01:17:06.050 --> 01:17:10.660 where the rate can change based on what that formula is. 01:17:10.660 --> 01:17:13.300 And that can be as we talked about the time of use, 01:17:13.300 --> 01:17:17.753 where that rate is based on gas prices or something else. 01:17:18.938 --> 01:17:23.827 So, just wanna make sure that you think that variable plans 01:17:27.980 --> 01:17:29.170 that have always been in he market 01:17:29.170 --> 01:17:32.280 that are essentially just a month-to month-rate 01:17:32.280 --> 01:17:33.880 that the customer can get out of at any time 01:17:33.880 --> 01:17:36.130 if they don't like what that upcoming rate is. 01:17:36.130 --> 01:17:37.277 Is not up for discussion. 01:17:37.277 --> 01:17:39.780 So, a key nuance is, 01:17:39.780 --> 01:17:42.010 when do you pay for the ancillary services? 01:17:42.010 --> 01:17:43.520 When you renew for the next month? 01:17:43.520 --> 01:17:45.220 Is that baked into that point? 01:17:45.220 --> 01:17:48.410 Or do you get the hit at the end? 01:17:48.410 --> 01:17:50.320 When do you get the hit of the ancillary services charge? 01:17:50.320 --> 01:17:51.379 Well, I'll say my understanding, 01:17:51.379 --> 01:17:54.670 is that I'm not aware of residential customers 01:17:54.670 --> 01:17:57.773 getting any pass-throughs of ancillary services. 01:17:58.720 --> 01:17:59.570 Yeah, as I understand it, 01:17:59.570 --> 01:18:02.040 I think that the customer knows what the rate is gonna be 01:18:02.040 --> 01:18:03.263 for each upcoming month. 01:18:04.350 --> 01:18:06.730 So, it would be, you wouldn't have paid a higher rate 01:18:06.730 --> 01:18:08.283 than you anticipated for, 01:18:09.270 --> 01:18:11.020 the month that you already use the electricity for it. 01:18:11.020 --> 01:18:12.110 That's the question, 01:18:12.110 --> 01:18:14.720 you would see it when you're renegotiating that next month, 01:18:14.720 --> 01:18:15.890 because you're on month to month 01:18:15.890 --> 01:18:17.130 and you're gonna see that ancillary service 01:18:17.130 --> 01:18:18.960 and you have the ability to, it's like, hey, I'm out, 01:18:18.960 --> 01:18:21.650 I'm going and I'm gonna get on a fixed rate plan somewhere. 01:18:21.650 --> 01:18:22.483 Right, and I think- 01:18:22.483 --> 01:18:23.970 How long do you have to choose? 01:18:23.970 --> 01:18:25.180 Yeah, I don't know. 01:18:25.180 --> 01:18:26.390 I mean, it's a month-to-month, right? 01:18:26.390 --> 01:18:28.160 You can get out at any time 01:18:28.160 --> 01:18:32.131 before that next month's different rate goes into it. 01:18:32.131 --> 01:18:32.964 But does it matter? 01:18:32.964 --> 01:18:34.880 When you see the next price for next month, 01:18:34.880 --> 01:18:37.300 like, do you get it on the 31st at midnight, 01:18:37.300 --> 01:18:38.747 or do you get 15th? 01:18:39.998 --> 01:18:42.410 There, I forget the exact timeline, 01:18:42.410 --> 01:18:47.160 but there's already requirements for how much of a heads up 01:18:47.160 --> 01:18:49.615 that the reps have to provide the customers. 01:18:49.615 --> 01:18:54.133 And Christina, has the exact timelines really quickly. 01:18:55.860 --> 01:18:57.920 Hey, Christina Rollins with NRG. 01:18:57.920 --> 01:18:59.840 So, for a variable rate product in the market, 01:18:59.840 --> 01:19:03.350 a rep is obligated to show the customer the current rate 01:19:03.350 --> 01:19:06.530 and make that rate available to the customer at all times. 01:19:06.530 --> 01:19:08.820 They also have to show the one-year historical price 01:19:08.820 --> 01:19:11.540 of that product, so that way, the customer can see, well, 01:19:11.540 --> 01:19:13.300 what does that product do over the course of a year, 01:19:13.300 --> 01:19:14.470 so I can better understand 01:19:14.470 --> 01:19:16.460 what it means to sign up for that product? 01:19:16.460 --> 01:19:19.120 So, they should be able to go either call their rep, 01:19:19.120 --> 01:19:21.070 or access their current price online 01:19:21.070 --> 01:19:22.670 so they can see that to determine, 01:19:22.670 --> 01:19:23.980 do I wanna stay on this product 01:19:23.980 --> 01:19:25.920 or do I wanna move to something else? 01:19:25.920 --> 01:19:27.380 And like Carrie said, 01:19:27.380 --> 01:19:28.970 the price where a variable rate product 01:19:28.970 --> 01:19:31.640 holds true for the entire billing cycle. 01:19:31.640 --> 01:19:33.870 So, it's not the scenario like what the index products 01:19:33.870 --> 01:19:37.100 where the price literally was changing hour by hour 01:19:37.100 --> 01:19:39.283 or every 15 minutes, day by day 01:19:39.283 --> 01:19:41.800 during the course of a Winter Storm Uri. 01:19:41.800 --> 01:19:44.300 So, that's what the index price formula lets you do, 01:19:44.300 --> 01:19:45.680 is you can have a different price 01:19:45.680 --> 01:19:47.830 from a day-to-day perspective. 01:19:47.830 --> 01:19:50.350 And so, that's kind of the real difference. 01:19:50.350 --> 01:19:53.163 But when, so, if in January, 01:19:54.775 --> 01:19:57.013 the oil's price is gonna be eight cents, 01:19:58.759 --> 01:20:00.683 but it can change in February. 01:20:01.580 --> 01:20:03.100 When does he find out 01:20:03.100 --> 01:20:06.780 that it's gonna be 15 cents in February? 01:20:06.780 --> 01:20:08.970 So, reps approach that differently. 01:20:08.970 --> 01:20:13.593 Some reps we'll let the customer know for quite some time 01:20:13.593 --> 01:20:16.640 what the price will be for their next bill. 01:20:16.640 --> 01:20:19.550 And some reps I guess, could in theory, 01:20:19.550 --> 01:20:21.330 based on what the rule says today, 01:20:21.330 --> 01:20:24.080 wait until right before that billing cycle 01:20:24.080 --> 01:20:25.170 to change the price. 01:20:25.170 --> 01:20:28.240 So, if you were looking at how long in advance, 01:20:28.240 --> 01:20:31.840 you want the person to know that price, 01:20:31.840 --> 01:20:33.030 that is something you could look at 01:20:33.030 --> 01:20:35.260 probably in this existing rule. 01:20:35.260 --> 01:20:38.330 So, the regular variable rate product 01:20:38.330 --> 01:20:40.160 that's in our current rule. 01:20:40.160 --> 01:20:41.183 One thing to note, 01:20:42.890 --> 01:20:45.643 it's existed in our role for a long time. 01:20:46.620 --> 01:20:49.450 The month-to-month aspect of the rate product 01:20:49.450 --> 01:20:54.250 is actually there are a lot of low-income consumers 01:20:54.250 --> 01:20:56.840 that sign up for month to month variable rate products. 01:20:56.840 --> 01:21:00.210 And that's one benefit that I think of the product, 01:21:00.210 --> 01:21:02.990 even though it can vary from month to month. 01:21:02.990 --> 01:21:07.120 My understanding based on prior review of these products, 01:21:07.120 --> 01:21:08.960 so, when we were looking at them back at OPEC 01:21:08.960 --> 01:21:10.020 after the storm, 01:21:10.020 --> 01:21:12.680 is that they have their place in the market 01:21:12.680 --> 01:21:15.990 because of the sort of flexibility to provide customers 01:21:15.990 --> 01:21:17.930 and low-income customers. 01:21:17.930 --> 01:21:19.410 I personally not trying to get rid 01:21:19.410 --> 01:21:21.130 of the variable rate product, 01:21:21.130 --> 01:21:23.190 I just don't want ancillary service charges pass through 01:21:23.190 --> 01:21:25.340 to residential, small commercial customers. 01:21:27.770 --> 01:21:29.460 I think that's clear, 01:21:29.460 --> 01:21:31.250 and we'll prepare a draft consistent 01:21:31.250 --> 01:21:33.630 with your discussion today. 01:21:33.630 --> 01:21:34.671 No, it works for me. 01:21:34.671 --> 01:21:35.580 It works for me. 01:21:35.580 --> 01:21:37.120 If we also a staff 01:21:37.120 --> 01:21:41.803 to consider some requirement of next month notification, 01:21:42.870 --> 01:21:45.600 so that in theory, on a variable rate, 01:21:45.600 --> 01:21:50.600 you can't get your next month price at midnight on the 31st. 01:21:54.090 --> 01:21:54.923 The other thing too, 01:21:54.923 --> 01:21:57.410 I think there was legislation that was passed 01:21:57.410 --> 01:22:00.100 that created a default renewal product 01:22:00.100 --> 01:22:02.360 because of this situation with variable rate products 01:22:02.360 --> 01:22:04.488 that there was some protective measures put in place to, 01:22:04.488 --> 01:22:07.327 and Connie, do you wanna speak to that a little bit? 01:22:08.730 --> 01:22:09.590 Yes. 01:22:09.590 --> 01:22:11.870 We'll go back through the comments and take a look. 01:22:11.870 --> 01:22:15.250 This is not a part of the rule 01:22:15.250 --> 01:22:18.980 that we received comments on necessarily, 01:22:18.980 --> 01:22:21.300 and was not noticed in our proposal, 01:22:21.300 --> 01:22:23.743 but we'll go back and take a look at that. 01:22:24.860 --> 01:22:27.830 And again, I just wanna remind all of our guests 01:22:27.830 --> 01:22:30.850 that before I'm here today, 01:22:30.850 --> 01:22:34.040 is for staff to dialogue with the Commissioners 01:22:34.040 --> 01:22:35.810 and make sure staff is producing the work 01:22:35.810 --> 01:22:37.220 Commissioners expect, 01:22:37.220 --> 01:22:41.380 not to rework shop the entire customer protection rule. 01:22:41.380 --> 01:22:42.920 Yeah, we'll go through all the comments 01:22:42.920 --> 01:22:44.190 that were already filed. 01:22:44.190 --> 01:22:45.023 Yes. 01:22:45.023 --> 01:22:46.162 Thank you. 01:22:46.162 --> 01:22:47.579 What type of the. 01:22:49.640 --> 01:22:50.473 Yes, sir. 01:22:50.473 --> 01:22:52.930 Thank you, Michael Juul on behalf of Octopus Energy. 01:22:52.930 --> 01:22:53.763 And Chairman Lake, 01:22:53.763 --> 01:22:55.900 we would strongly encourage your recommendation 01:22:55.900 --> 01:22:59.060 that there be prior notice with regard to variable rates. 01:22:59.060 --> 01:23:01.460 So, the customers know before the month starts, 01:23:01.460 --> 01:23:03.320 what they're going to be charged. 01:23:03.320 --> 01:23:04.153 Thank you, sir. 01:23:04.153 --> 01:23:04.986 Thank you. 01:23:04.986 --> 01:23:06.840 That's not in the scope of this boat. 01:23:06.840 --> 01:23:07.673 Something we'll take up- 01:23:07.673 --> 01:23:10.380 We've put comments on that in this as well. 01:23:10.380 --> 01:23:12.227 We'll look at it, thank you, sir, thank you. 01:23:13.690 --> 01:23:14.590 Anything else, Mr. 01:23:15.520 --> 01:23:16.620 I think that's good. 01:23:17.510 --> 01:23:21.197 I think that the next thing (indistinct) 01:23:22.460 --> 01:23:26.923 That'll conclude business on 10, and we're not doing 11. 01:23:29.833 --> 01:23:34.013 I don't have anything, there's nothing on 12 through 17. 01:23:36.762 --> 01:23:41.762 That brings us to 19, 18 will be after the break, 19. 01:23:41.925 --> 01:23:43.008 Mr. Smeltzer. 01:23:43.920 --> 01:23:48.500 Hello, this is coming back to our proposal 01:23:48.500 --> 01:23:50.990 for adoption for review of 25.505. 01:23:50.990 --> 01:23:53.510 This is the HCAP rule 01:23:53.510 --> 01:23:58.510 staff has prepared the $5,000 cap draft 01:23:58.690 --> 01:24:02.033 as directed using some very Pythian and genius language 01:24:02.033 --> 01:24:04.180 for the justification 01:24:04.180 --> 01:24:06.640 that we've incorporated into the analysis in the preamble. 01:24:06.640 --> 01:24:09.049 And it is prepared for your adoption. 01:24:09.049 --> 01:24:12.632 I would just note, this is project 52631. 01:24:15.243 --> 01:24:17.202 We covered this earlier this week, 01:24:17.202 --> 01:24:19.869 other than the Pythian language. 01:24:20.760 --> 01:24:23.690 I love the number, it works for me. 01:24:23.690 --> 01:24:24.523 There you go. 01:24:24.523 --> 01:24:25.356 Any other thoughts on this, 01:24:25.356 --> 01:24:29.370 or a motion to approve the proposal for adoption? 01:24:29.370 --> 01:24:30.203 So moved. 01:24:30.203 --> 01:24:31.036 Second. 01:24:31.036 --> 01:24:32.000 All in favor, say aye. 01:24:32.000 --> 01:24:32.833 Aye. Aye. 01:24:32.833 --> 01:24:36.940 Chairman, I just wanted to be very clear on the record, 01:24:36.940 --> 01:24:38.750 that is your expectation, 01:24:38.750 --> 01:24:43.483 this HCAP will be implemented on January 1st. 01:24:44.530 --> 01:24:45.363 Yes. 01:24:45.363 --> 01:24:47.800 At the request of ERCOT for clarification. 01:24:47.800 --> 01:24:48.633 Yes. 01:24:48.633 --> 01:24:49.860 Yes, great. Thank you. 01:24:49.860 --> 01:24:51.610 All intend this to be implemented 01:24:52.860 --> 01:24:57.360 on, or before January 1st motion has passed. 01:24:57.360 --> 01:25:00.573 Thank all of you all, and especially staff. 01:25:01.820 --> 01:25:05.320 This was a very, very quick turnaround in order to make sure 01:25:05.320 --> 01:25:07.170 that it could be implemented by January 1st 01:25:07.170 --> 01:25:11.354 before the price, the HCAP resets to 9,000. 01:25:11.354 --> 01:25:14.268 Like, many, many, thanks for all the work on this. 01:25:14.268 --> 01:25:15.410 Thank you. 01:25:15.410 --> 01:25:16.660 Thank you. 01:25:16.660 --> 01:25:19.977 Nothing on items 23, 26, 01:25:21.074 --> 01:25:25.393 and it brings us to, 01:25:25.393 --> 01:25:28.010 I think that brings us to item number 29, 01:25:28.010 --> 01:25:29.073 project number 52805. 01:25:31.609 --> 01:25:33.573 And Mr. Smeltzer, you're back up. 01:25:37.270 --> 01:25:39.073 I thought there might've been one in there. 01:25:40.720 --> 01:25:44.130 This is a proposal for publication that we have for you 01:25:44.130 --> 01:25:47.743 for review of 16 PAC 27.170. 01:25:49.790 --> 01:25:51.090 We refer to it as the Jay rule. 01:25:51.090 --> 01:25:53.030 As far as we know, it just affects Jay Stone 01:25:53.030 --> 01:25:53.863 and no one else. 01:25:53.863 --> 01:25:56.340 So, this is to pull our advanced contracting 01:25:56.340 --> 01:25:59.100 monitoring practices in line with statute, 01:25:59.100 --> 01:26:00.440 excuse me, to pull our rule 01:26:00.440 --> 01:26:03.280 in line with statute in our current practices. 01:26:03.280 --> 01:26:05.580 This is just a codified current practices sort of deal, 01:26:05.580 --> 01:26:08.670 there's not too much to say, but Jay's available 01:26:08.670 --> 01:26:09.807 should we have any questions. 01:26:09.807 --> 01:26:10.807 All right. 01:26:13.415 --> 01:26:14.733 I think this conforms to, 01:26:16.271 --> 01:26:19.340 we go to any thoughts, comments, 01:26:19.340 --> 01:26:21.810 or a motion to approve the proposal for publication? 01:26:21.810 --> 01:26:23.010 So moved. 01:26:23.010 --> 01:26:24.060 Second. 01:26:24.060 --> 01:26:24.983 All right. 01:26:26.500 --> 01:26:27.333 All in favor, say, aye. 01:26:27.333 --> 01:26:28.720 Aye. Aye. 01:26:28.720 --> 01:26:31.060 None opposed, motion passes. 01:26:31.060 --> 01:26:32.140 All right, thank you, sir. 01:26:32.140 --> 01:26:33.363 Thank you. Thank you, Jay. 01:26:34.420 --> 01:26:38.393 Item 30, we've got an update from our executive director. 01:26:39.320 --> 01:26:40.480 Thank you, Mr. Chairman. 01:26:40.480 --> 01:26:42.740 Commissioners, just a couple updates this morning. 01:26:42.740 --> 01:26:44.710 First, I am happy to report 01:26:44.710 --> 01:26:47.900 that we have filled our director of communications position, 01:26:47.900 --> 01:26:50.490 Rich Parsons has accepted the job, 01:26:50.490 --> 01:26:53.260 he has a wealth of experience, 01:26:53.260 --> 01:26:55.420 he's a former newscaster 01:26:55.420 --> 01:26:58.149 and previously worked at the Railroad Commission 01:26:58.149 --> 01:26:59.390 and currently works 01:26:59.390 --> 01:27:02.109 as the Director of Communications at HHSC. 01:27:02.109 --> 01:27:05.130 We hit a home run with this hire, I'm glad to say 01:27:05.130 --> 01:27:08.630 this is the equivalent of getting a five-star recruit, 01:27:08.630 --> 01:27:11.420 which for those of you who follow Texas football, 01:27:11.420 --> 01:27:12.800 explain what a five-star recruit is, 01:27:12.800 --> 01:27:14.650 it's someone who comes in 01:27:14.650 --> 01:27:18.239 and really helps our teams succeed in the near and longterm. 01:27:18.239 --> 01:27:22.080 So, yeah, we're blessed to have him come 01:27:22.080 --> 01:27:24.110 and be a part of our team, 01:27:24.110 --> 01:27:26.220 he he'll begin at the beginning of January. 01:27:26.220 --> 01:27:27.053 You should get used to, 01:27:27.053 --> 01:27:29.960 you should look to baseball, or football. 01:27:29.960 --> 01:27:30.831 No, it's a great analogy, 01:27:30.831 --> 01:27:31.664 I'm just glad 01:27:31.664 --> 01:27:33.840 he doesn't have to sit out a year before transferring. 01:27:33.840 --> 01:27:36.150 That's true, we couldn't handle that, 01:27:36.150 --> 01:27:39.353 I don't think my co would've let me do that, so. 01:27:40.700 --> 01:27:42.390 And the second item of note, 01:27:42.390 --> 01:27:44.360 is dealing with our mapping committee. 01:27:44.360 --> 01:27:46.740 As you know, I chair that committee, 01:27:46.740 --> 01:27:49.830 we have a report due on January 1st 01:27:49.830 --> 01:27:51.900 that that's a statutory deadline. 01:27:51.900 --> 01:27:54.320 We'll be preparing that and getting it approved, 01:27:54.320 --> 01:27:56.190 hopefully at our December meeting, 01:27:56.190 --> 01:27:59.120 which I think will be on the 17th of this month. 01:27:59.120 --> 01:28:00.930 And then I wanna publicly thank 01:28:00.930 --> 01:28:01.960 the members of that committee. 01:28:01.960 --> 01:28:04.040 I asked that we have our January meeting 01:28:04.040 --> 01:28:04.880 be a public meeting, 01:28:04.880 --> 01:28:06.780 even though it's not required by statute. 01:28:06.780 --> 01:28:09.670 I think it's important for us to publicly update everyone 01:28:09.670 --> 01:28:11.520 on what our work has been. 01:28:11.520 --> 01:28:12.353 So, at that meeting, 01:28:12.353 --> 01:28:14.620 which will be sometime in the middle of January, 01:28:14.620 --> 01:28:15.690 we'll go over the report 01:28:15.690 --> 01:28:18.310 and get updates from our project teams 01:28:18.310 --> 01:28:20.180 on everything that's been going on 01:28:20.180 --> 01:28:22.270 and what we hope to do going forward. 01:28:22.270 --> 01:28:24.830 And one of the other requests that I wanna thank them for, 01:28:24.830 --> 01:28:26.440 is there's a statutory deadline 01:28:26.440 --> 01:28:29.360 at the first map be completed September 1st. 01:28:29.360 --> 01:28:32.593 I've asked our staff, Railroad staff, Tetum and ERCOT 01:28:32.593 --> 01:28:36.050 that we produced that first map no later than April, 01:28:36.050 --> 01:28:38.390 there are a number of other items in Senate Bill 3 01:28:38.390 --> 01:28:40.570 that are pegged to that first map, 01:28:40.570 --> 01:28:43.120 including some weatherization rules at other agencies. 01:28:43.120 --> 01:28:46.050 And so, everyone agreed that the first map 01:28:46.050 --> 01:28:48.310 would be out no later than April 1st, 01:28:48.310 --> 01:28:51.363 and I wanna thank them for agreeing to what I asked for. 01:28:52.610 --> 01:28:54.560 Outstanding on all fronts, but the higher, 01:28:54.560 --> 01:28:57.150 the accelerated pace of work on the mapping committee, 01:28:57.150 --> 01:28:59.190 I appreciate all of that work, 01:28:59.190 --> 01:29:02.855 except y'all's (indistinct) for that joke. 01:29:02.855 --> 01:29:07.130 Oh no, no, I appreciate. 01:29:07.130 --> 01:29:08.506 Mr. Janae, we'll get to see, 01:29:08.506 --> 01:29:10.920 when his team joined CSCC, 01:29:10.920 --> 01:29:12.107 what five-start recruiting looks like. 01:29:12.107 --> 01:29:13.720 That's a good skid 01:29:13.720 --> 01:29:17.010 to talk about trading dads and families analogies 01:29:17.010 --> 01:29:18.787 to trading coaches and football. 01:29:18.787 --> 01:29:21.095 All right, thank you. What are you saying. 01:29:21.095 --> 01:29:23.689 (members laughing) 01:29:23.689 --> 01:29:27.400 That concludes business, sir, I am sorry. 01:29:27.400 --> 01:29:32.400 We have convened in a duly notice open meeting. 01:29:32.740 --> 01:29:33.930 So, the Commission will now, 01:29:33.930 --> 01:29:38.930 at 11:02 a.m. on December 2nd, 2021, hold a closed session 01:29:39.950 --> 01:29:42.380 pursuant to Chapter 501 of the Texas Government code, 01:29:42.380 --> 01:29:45.707 the section 551.071, 551.074 and 551.076. 01:29:48.220 --> 01:29:50.280 In that time, we will rearrange the room 01:29:50.280 --> 01:29:55.280 and prepare for our second half of programming today 01:29:55.660 --> 01:29:57.860 at our work session, 01:29:57.860 --> 01:30:01.150 or to make sure we have adequate time for all of the above, 01:30:01.150 --> 01:30:03.233 let's plan on reconvening at noon. 01:30:04.500 --> 01:30:05.333 Thank y'all.