WEBVTT
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(tapping gavel thrice)
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Good morning.
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This meeting with the Public Utility Commission of Texas
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will come to order to consider matters that have been duly
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posted with the Secretary of State of Texas
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for June 30th, 2022.
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For the record, my name is Peter Lake
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and with me today, are Will MCAdams,
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Lori Cobos and Jimmy Gloftfelty.
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Mr. Jenay, could you please walk us through
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the consent items on today's agenda?
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Good morning Commission.
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By individual ballot,
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the following items were placed on your Consent Agenda.
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Two, three, four, six. nine, 11, 13, 17, 18, 19, 23 and 27.
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Thank you, sir.
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We have a motion to approve the items just
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described by Mr. Jenay.
So moved.
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Second.
Second.
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All in favor, say aye.
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Aye.
Aye.
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None opposed, motion passes.
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We will not be taking up item five today,
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and that brings us to our formal agenda.
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First item is public comment,
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oral comments related to specific agenda items as always
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will be heard when that item is taken up.
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This segment is for general comments only.
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When we do get to oral comments on specific agenda
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items, stakeholders should not approach the table
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unless oral argument has been granted,
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or they have been invited by a Commissioner.
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As always, speakers will be limited to three minutes each.
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Mr. Jenay, do we have anyone from the public
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signed up to speak?
No, sir.
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This morning, no one is signed up.
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Thank you, sir.
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In that case, public comment is now closed.
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Next item on our agenda please, Mr. Jenay.
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I believe it is item number seven, Docket 52707.
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Petition of Sheryl Lynn Lane Dowell,
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Trustee of the Dan Dowell Credit Trust to amend,
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some water supply corporation's name I can't say.
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convenience and necessity in Collin County
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by expedited release.
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Proposed order was filed on March 16th.
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Thank you, sir.
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Thoughts, comments on the docket, now Mr. Jenay.
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I think this is straightforward.
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I think my, from my perspective,
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I think we reject a proposed order remanded back
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to obtain additional information on who owns
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the County Road 398 and determine whether the track of land
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can be released through streamlined expedite release,
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given the fact that the County Road severs
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the track into two.
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So there's a factual issue that we need to address
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in order to be able to move forward with
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considering this application.
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Yeah, that makes sense to me.
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Yeah. Mr. Chairman, I would agree with that.
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And also as a further refinement who has title
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to what's below County Road 398 as well.
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So I'd support that.
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I feel the same way, thanks.
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All right, Commissioner Cobos sounds like
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you have a motion.
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Yes, I have a motion to reject the proposal order
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to remand the case back to obtain additional information
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on who owns County Road 398 and determine whether
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the track of land can be released through the stream on
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expedite a release requirements
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under the Texas Water Code and Commission Rules.
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Do we have a second.
Second.
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All in favor, say aye.
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Can we make sure that that motion does have what
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Commissioner MCAdams said,
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which is the land underneath the road?
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Yes.
Very formally.
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As the issues evaluated for ownership of the County Road
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to look at ownership, both I guess,
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above and underneath the road.
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Yes, I think that was the intent.
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Second.
Right.
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Yes.
Amended motion seconded.
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All in favor, say aye.
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Aye.
Aye.
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None opposed, motion passes.
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Next item please, Mr. Jenay.
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Item eight is Docket 52758 is petition of McAllen
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public utility appealing wholesale water rates charged
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by Hidalgo County Water Improvement, District No. 3.
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Before you is an appeal of so order number four.
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Thank you, sir.
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Thoughts, comments.
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Mr. Chairman look, the abatement requirement
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under 16 T.A.C 24307, subsection D
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has been subject to multiple court cases
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since the Commission adopted the rule.
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Without changes from its promulgation
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by the Water Commission in the mid 1990s.
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And now with the enactment
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of the Water Code 12.013, subsection D.
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It is unclear whether the 16 T.A.C 24307 requirement
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to abate wholesale rate proceedings so that the parties
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may bring the court action to determine if the appealed
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rates are pursuant to the contract
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is currently valid or necessary.
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So I would propose moving to extend time to act
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on the appeal of so order number four,
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until the Commission can decide to act on the appeal.
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Open ended so that once that's settled, we can readdress.
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Well, makes sense is a,
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an issue that needs to have some time spent on it.
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Agreed.
Agreed.
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All right, consider that your motion?
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That is my motion.
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We have a second?
Second.
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All in favor, say aye.
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Aye.
Aye.
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None opposed, motion passes.
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Next item please, sir.
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Item 10 is Docket 52892, the application of East Houston
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Utilities for a Class D Rate Adjustment.
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Proposed order was filed on March 29th.
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Thank you, sir.
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Thoughts, comments.
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Hey, here's another one for me.
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Another thought Mr. Chairman,
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the PFD would dismiss East Houston's application for failure
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to amend its application such that it is sufficient
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after repeated determinations, that it was insufficient.
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The only deficiency identified by the Commission staff
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requested East Houston to submit proof that it is eligible
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for one of the exemptions listed
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under 16 T.A.C 24.29, subsection B.
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However, that rule provision applies to the filing
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of a statement of intent under the Water Code 13.1871
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and 13.18715.
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So it does not apply to the applications for a Class D
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Utility rate adjustment under the Water Code 131872.
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So with that, I'd kind of frame this in a motion to remand
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the proceeding for additional processing based on
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the Commission's determination that 16 T.A.C 24.29
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subsection B, does not apply to an application
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for a Class D rate adjustment filed
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under the Water Code under 13.1872.
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If you're referring to the 12 month consideration
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and the difference between the adjustment and the case--
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That's correct.
I agree with that.
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I don't have the numbers quite as well memorized as you do.
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I was gonna say the exact same thing
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that Commissioner MC Adam said.
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I got it sir.
Verbatim.
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Verbatim number by numbers, statue citation as such.
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I think I'm on the same page as I understand it.
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I think with Commissioner McAdams,
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we need to remand the PFD.
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I'm sorry, reject the PFD and remand the case back
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so that the case can be evaluated into the rate adjustment
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requirements under the Water Code instead of the base rate.
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Not the rate setting.
Yeah, exactly.
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Proceed.
Because staff's position
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on recommending the application because it's deficient
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was based on the base rate case requirements
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and the case needs to get remanded back
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so that the appropriate standard of review
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and requirements are applied for a rate adjustment
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rather than base rate case is small water utility,
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is clearly your rate adjustment.
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So I think that's the appropriate action.
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Agreed, do you have a motion for us?
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I do.
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So I would move to remand the proceeding for additional
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processing based on the Commission's determination
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that 16 T.A.C 24.29 subsection B
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does not apply to an application for a Class D
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rate adjustment filed under the Water Code
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section 13.1872.
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We have a second.
Second.
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All in favor, say aye.
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Aye.
Aye.
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None opposed, thank you, Commissioner McAdams.
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Next item please, sir.
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I don't think we have anything.
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11 was consented 12.
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I don't have anything until I think item 15.
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Is that consistent with your account, Mr. Jenay?
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Yes, sir.
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Item 15 is Docket 51665.
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Application of Southwestern Public Service Company
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to change its fuel factors.
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First announced Commissioner Cobos has recused herself
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from this matter.
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Proposed order was filed on June 10th.
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Thank you, sir.
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Thoughts, comments, bit of a tricky one.
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I think we're just implementing something that we've
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previously decided, we've approved the formula.
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Now we're specifically putting this to the right structure.
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And I think that eliminating that component of the fuel
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factor that was dedicated to Winter Storm Uri
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is not appropriate to get a real baseline
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for what the fuel factor is.
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So I would suggest that we approve this.
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Well put.
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So with that, Mr. Chairman, I agree in the concept,
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I believe that first issue good course.
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Yes.
Without good course,
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we have a situation where our utility
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may materially under earn.
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So I believe that under the proposed order,
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the good course should be granted.
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You agree.
Okay.
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As to the adoption of the proposed order.
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So I believe the issue of supporting evidence
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has not been satisfied.
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So I believe that we should take no action on the proposed
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order, but potentially remand this back.
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So that SPS has the opportunity to provide supporting
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evidence such as work papers so that we establish
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the record on this.
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I'm supportive of that.
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Okay.
Makes sense to me.
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Yeah, that makes sense to me.
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It certainly the under recovery would be a staggering number
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if we didn't grant that good course exception.
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Right, all of that.
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But we do need to see, like in,
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as we've consistently asked in the number of proceedings,
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we wanna see the math on the rest of it.
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All right.
Same to same.
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So could I make a motion consistent with our conversation
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from the Dias, Mr. Jenay.
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Please.
So moved.
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Second.
All in favor, say aye.
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Aye.
Aye.
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None opposed, motion passes.
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Next item please, sir.
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Item 16 is Docket 52455.
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Application of Oncor Electric Delivery Company
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to amend its CCN for electric transmission line
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in Ellis County.
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A proposed order was filed on May 6th.
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The LJ filed a correction memo on May 17th.
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And I have a memo with proposed changes to the order.
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This is another proceeding where we've asked
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to see the homework and we've seen it.
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I suppose, thoughts comments?
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Well, first I'd like to thank the parties
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for filing testimony to support their settlement agreement
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in this case.
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Based on my review of the testimony, I would move to,
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from my perspective, I would approve the proposed order
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that adopts settlement agreement regarding
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agreed route number 152.
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And my position, from my standpoint,
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I believe the route from reliability standpoint
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provides pretty much the same reliability
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as Route 54.
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It is a little bit more expensive, 2.3 million,
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but I think when you look at the totality of the facts,
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this line is needed.
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This is about three to five mile line it's needed
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to interconnect about 223 megawatts
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of solar generation in ERCOT.
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The production cost savings that we would get
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from this new solar generation, the reliability benefits
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that it would provide, I think would be helpful
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and would be, I mean, I think it'd be fine to spend
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a little bit more money to get
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these generation facilities interconnected.
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From reliability standpoint, the line is,
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provides about the same reliability as the Route 54
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that was provided for an Oncor's application.
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Again, 2.3 million is not that much.
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It's a diminimous amount.
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And when you look at Oncor's entire rate base,
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regardless of the route that's chosen for this line,
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there will still be a 7.8 million cost
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for the switch station.
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And I think there are a variety of landowners are supportive
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of this green route, the largest landowners,
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and it's got a lot of community support, impact on community
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values and environmental effects are positive.
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And I think, we gotta get in a position where at some point,
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we need to view settlements from the lens of all the facts
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that we gotta take into consideration to approve a CCN.
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But also we don't want to consistently be sending cases back
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because if we send this case back,
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we would require the parties to have a hearing or come back
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with a settlement agreement.
00:13:55.620 --> 00:13:58.710
I'm not just, I'm not sure we're gonna get anything better.
00:13:58.710 --> 00:14:00.930
I think we just need to move forward and go ahead
00:14:00.930 --> 00:14:03.420
and approve the settlement agreement with the agreed route
00:14:03.420 --> 00:14:06.300
based on the rationale that I've provided.
00:14:06.300 --> 00:14:07.230
Thank you.
00:14:07.230 --> 00:14:08.253
Thoughts, comments.
00:14:09.600 --> 00:14:11.160
I'm in agreement.
00:14:11.160 --> 00:14:13.260
I was not here when you all discussed this,
00:14:13.260 --> 00:14:18.260
the first meeting I was out sick, but I do believe
00:14:18.810 --> 00:14:22.590
that we have definitely not an obligation,
00:14:22.590 --> 00:14:26.580
but a opportunity when parties settle to take that
00:14:26.580 --> 00:14:30.210
settlement and make it easy on them and on us.
00:14:30.210 --> 00:14:34.140
And it, to me, we've had a few of these,
00:14:34.140 --> 00:14:36.270
especially in transmission routing,
00:14:36.270 --> 00:14:38.820
the settlements mean higher costs.
00:14:38.820 --> 00:14:41.430
These are all estimates, quite frankly,
00:14:41.430 --> 00:14:43.233
a $2 million higher cost.
00:14:44.490 --> 00:14:48.390
I want all of our transmission costs to be real and low,
00:14:48.390 --> 00:14:51.480
but this could be inflation on steel.
00:14:51.480 --> 00:14:55.980
This could be a eminent domain proceeding if we reject this.
00:14:55.980 --> 00:14:58.410
I mean, there are lots of other things that can make up
00:14:58.410 --> 00:15:00.450
that difference if we don't adopt this.
00:15:00.450 --> 00:15:04.500
And getting more and more people to settle these cases,
00:15:04.500 --> 00:15:08.100
being willing to put our facilities on their land
00:15:08.100 --> 00:15:11.340
is really important I think for the future transmission
00:15:11.340 --> 00:15:12.210
development in Texas.
00:15:12.210 --> 00:15:15.393
So I'm supportive of Commissioner Cobos.
00:15:16.980 --> 00:15:18.723
Mr. Chairman, members.
00:15:20.610 --> 00:15:22.110
I feel like we're getting backed
00:15:22.110 --> 00:15:25.620
into a corner on reliability.
00:15:25.620 --> 00:15:28.620
That that word is gonna be thrown out around
00:15:28.620 --> 00:15:31.212
for quite some time in the Oncor system, because--
00:15:31.212 --> 00:15:34.020
Forever.
Yeah, well forever.
00:15:34.020 --> 00:15:37.680
But right now with the thin lay of the land
00:15:37.680 --> 00:15:40.800
in terms of resource adequacy, we're gonna be there.
00:15:40.800 --> 00:15:42.060
So we're gonna need to build lines
00:15:42.060 --> 00:15:44.490
and it's absolutely necessary.
00:15:44.490 --> 00:15:48.270
Even once 1281 is implemented a transmission rule
00:15:48.270 --> 00:15:51.240
on an economic benefit test is imposed.
00:15:51.240 --> 00:15:54.130
Reliability will stay still weigh very heavily
00:15:55.080 --> 00:15:56.790
in the Commission's considerations.
00:15:56.790 --> 00:16:01.230
And we will see a lot of projects
00:16:01.230 --> 00:16:05.193
that will fall within that methodology.
00:16:06.090 --> 00:16:11.010
And so I worry that we are being pressed
00:16:11.010 --> 00:16:11.880
from two directions.
00:16:11.880 --> 00:16:14.520
One, settlement with stakeholders.
00:16:14.520 --> 00:16:18.580
And I totally agree with trying to allow
00:16:19.680 --> 00:16:21.390
all of the conditions to be considered,
00:16:21.390 --> 00:16:25.890
which we are statutorily required to.
00:16:25.890 --> 00:16:28.320
All of the allowances and considerations
00:16:28.320 --> 00:16:31.500
for the property owners along proposed routes
00:16:31.500 --> 00:16:33.270
to be considered.
00:16:33.270 --> 00:16:37.960
But again, when costs and I see the point Commissioner Cobos
00:16:39.210 --> 00:16:43.020
on the aggregate are not much to the entire transmission
00:16:43.020 --> 00:16:45.630
cost of the Oncor system,
00:16:45.630 --> 00:16:47.940
but it's still 2.5 million more
00:16:47.940 --> 00:16:49.563
than the lowest cost route.
00:16:50.400 --> 00:16:53.790
The reliability benefits are the same, correct.
00:16:53.790 --> 00:16:56.040
I mean, that's what we found in the evidence.
00:16:57.900 --> 00:17:00.363
54 follows existing right away.
00:17:01.710 --> 00:17:06.710
And again, we are taking the settlement at phase value
00:17:06.960 --> 00:17:08.580
because it is a settlement.
00:17:08.580 --> 00:17:09.840
So everybody came to the table.
00:17:09.840 --> 00:17:12.510
Everybody can come to the table on a 50 billion project
00:17:12.510 --> 00:17:13.343
if they want to.
00:17:13.343 --> 00:17:14.926
I mean, they don't care.
00:17:14.926 --> 00:17:18.780
That's our job is to try to keep the lid on cost
00:17:18.780 --> 00:17:20.700
imposed to the system.
00:17:20.700 --> 00:17:24.630
And so, my view is this needs to be sent back
00:17:24.630 --> 00:17:26.550
and reviewed on the merits.
00:17:26.550 --> 00:17:30.693
That they have to go through the process to determine that.
00:17:33.060 --> 00:17:35.340
And anyway, that's just my view, Mr. Chairman.
00:17:35.340 --> 00:17:36.990
Well, and Commissioner MCAdams,
00:17:36.990 --> 00:17:39.120
I certainly appreciate your perspective.
00:17:39.120 --> 00:17:41.340
It's a constant balancing, right?
00:17:41.340 --> 00:17:43.380
We've had other CCN cases that come,
00:17:43.380 --> 00:17:47.610
they've been filed and we've looked at interconnection
00:17:47.610 --> 00:17:49.890
of generation facilities and reliability,
00:17:49.890 --> 00:17:52.040
and we gotta balance all these factors out.
00:17:53.400 --> 00:17:56.760
And each case will have its own factual circumstances
00:17:56.760 --> 00:17:57.810
for us to evaluate.
00:17:57.810 --> 00:18:01.680
And this, in this case, we have our facts
00:18:01.680 --> 00:18:04.860
and I understand where you're coming from in terms of,
00:18:04.860 --> 00:18:06.720
you know every case may involve interconnection
00:18:06.720 --> 00:18:09.180
of generation that could provide to reliability.
00:18:09.180 --> 00:18:12.720
But as I look at the overall facts of this case,
00:18:12.720 --> 00:18:15.600
that the size of the line, the need for the line,
00:18:15.600 --> 00:18:19.050
the fact that if we remanded back and there's a hearing
00:18:19.050 --> 00:18:20.070
or another settlement,
00:18:20.070 --> 00:18:22.170
we have no guarantee that they're gonna come in
00:18:22.170 --> 00:18:23.010
with a cheaper line.
00:18:23.010 --> 00:18:24.450
That's true.
We could ask for it,
00:18:24.450 --> 00:18:26.640
but we may not.
00:18:26.640 --> 00:18:29.220
And what it'll ultimately turn into is additional rate payer
00:18:29.220 --> 00:18:34.220
costs because that's just more litigation that that'll ensue
00:18:34.260 --> 00:18:38.430
as a result of just kind of sending it back
00:18:38.430 --> 00:18:39.720
and vetting it out more.
00:18:39.720 --> 00:18:44.720
Which I always supportive of trying to do our due diligence,
00:18:45.510 --> 00:18:49.860
but at the same time, we gotta get to a place where
00:18:49.860 --> 00:18:52.830
we get some transmission built in ERCOT
00:18:52.830 --> 00:18:55.380
to address these types of circumstances.
00:18:55.380 --> 00:18:57.690
I mean, ERCOT is not reviewing economic transmission
00:18:57.690 --> 00:18:58.800
projects right now.
00:18:58.800 --> 00:19:00.930
Because Senate bill 1281 is not implemented.
00:19:00.930 --> 00:19:04.410
This is a prime example of what would be reviewed under
00:19:04.410 --> 00:19:06.300
that transmission criteria.
00:19:06.300 --> 00:19:07.650
Production, cost savings,
00:19:07.650 --> 00:19:09.750
solar generation being integrated in.
00:19:09.750 --> 00:19:14.073
And so we need to,
00:19:16.020 --> 00:19:17.010
from my perspective,
00:19:17.010 --> 00:19:19.590
given the facts and circumstances is case,
00:19:19.590 --> 00:19:22.860
and I think that I would be comfortable moving forward
00:19:22.860 --> 00:19:27.860
because I mean, we've gotta kind of get in the position
00:19:28.950 --> 00:19:30.600
where, well, we don't wanna get back into the corner
00:19:30.600 --> 00:19:32.610
with settlement agreements and they may be more high price.
00:19:32.610 --> 00:19:35.970
We'll evaluate every, all the facts at that time.
00:19:35.970 --> 00:19:37.020
And based on the facts here,
00:19:37.020 --> 00:19:40.200
I just think that moving forward with approving
00:19:40.200 --> 00:19:42.600
the settlement is probably more beneficial than continuing
00:19:42.600 --> 00:19:44.763
to grind it out over $2.3 million.
00:19:45.750 --> 00:19:49.300
Where the $2.3 million you can view as
00:19:51.030 --> 00:19:53.460
being balanced out by the additional generations
00:19:53.460 --> 00:19:54.860
being brought on the system.
00:19:56.520 --> 00:20:00.330
Yeah, I think my experience is that when you are trying
00:20:00.330 --> 00:20:03.390
to route a transmission line, it, first of all,
00:20:03.390 --> 00:20:04.620
it's not easy.
00:20:04.620 --> 00:20:07.380
You've got spaghetti maps, you've got lots of landowners,
00:20:07.380 --> 00:20:12.180
you've got historical environmental,
00:20:12.180 --> 00:20:13.680
all sorts of different factors
00:20:13.680 --> 00:20:15.480
that you're trying to resolve.
00:20:15.480 --> 00:20:17.850
And it's very hard and it's time consuming
00:20:17.850 --> 00:20:19.260
and it's expensive.
00:20:19.260 --> 00:20:24.260
So when we have parties come together and help us
00:20:25.440 --> 00:20:26.460
with that process,
00:20:26.460 --> 00:20:29.910
I think if there's a band of reasonableness around that cost
00:20:29.910 --> 00:20:32.710
increase to me, it behooves us to take that opportunity
00:20:33.750 --> 00:20:34.923
and benefit them.
00:20:36.090 --> 00:20:38.574
And I think that's where I'm supportive
00:20:38.574 --> 00:20:41.853
of Commissioner Cobos and think that we ought proof this.
00:20:44.073 --> 00:20:46.860
Does the Commission, Commissioner MCAdams
00:20:46.860 --> 00:20:51.120
there need to be difference in a economics benefit test,
00:20:51.120 --> 00:20:55.140
say by in the circumstance of relieving existing congestion
00:20:55.140 --> 00:20:58.260
without adding new generation, stand apart
00:20:58.260 --> 00:21:01.173
from adding new generation here and now.
00:21:03.030 --> 00:21:07.440
Well, all--
At this moment in time,
00:21:07.440 --> 00:21:09.353
not study to the state.
Exactly.
00:21:11.970 --> 00:21:13.282
I don't know.
00:21:13.282 --> 00:21:17.757
I'm not qualified to weigh the hypothetical Mr. Chairman.
00:21:17.757 --> 00:21:21.960
I would say my view would probably change if this was
00:21:21.960 --> 00:21:24.333
a peaker plant or something like that,
00:21:24.333 --> 00:21:25.980
that we were gonna call upon, but on aggregate,
00:21:25.980 --> 00:21:27.810
the solar facility will help the system
00:21:27.810 --> 00:21:28.810
and we are grateful.
00:21:29.820 --> 00:21:32.973
But given our near term needs,
00:21:33.990 --> 00:21:38.100
some are just a lot more useful for liability than others.
00:21:38.100 --> 00:21:39.390
And--
Well.
00:21:39.390 --> 00:21:40.680
Yeah, I mean, but during the summer,
00:21:40.680 --> 00:21:42.960
I don't think anybody can disagree that solar generation
00:21:42.960 --> 00:21:44.670
provides very high level of reliability.
00:21:44.670 --> 00:21:46.620
They're great in the summer, not much help in the winter.
00:21:46.620 --> 00:21:47.954
But we gotta take it where we can.
00:21:47.954 --> 00:21:48.900
Absolutely take it where we can.
00:21:48.900 --> 00:21:49.733
Every season's important.
00:21:49.733 --> 00:21:54.733
So again, that's not my reason for expressing concern.
00:21:54.840 --> 00:21:56.700
It is a cost issue.
00:21:56.700 --> 00:21:59.220
It's a big old dog leg, right.
00:21:59.220 --> 00:22:03.960
I mean, that route took, and I'm just trying to figure out,
00:22:03.960 --> 00:22:06.330
all right, what are we doing here on these settlements?
00:22:06.330 --> 00:22:10.860
And maybe it's enough that I've just rattled the cage
00:22:10.860 --> 00:22:13.680
and expressed concern, 'cause I think we're gonna see
00:22:13.680 --> 00:22:18.570
more of these and because reliability isn't ever present,
00:22:18.570 --> 00:22:20.943
pressure for all the systems right now.
00:22:21.840 --> 00:22:22.680
Well, absolutely.
00:22:22.680 --> 00:22:27.090
And as we look to implement Senate bill 1281 in our project,
00:22:27.090 --> 00:22:28.110
that staff is open.
00:22:28.110 --> 00:22:30.030
I mean, we're gonna be addressing
00:22:30.030 --> 00:22:31.590
additional reliability criteria.
00:22:31.590 --> 00:22:33.300
Correct.
Any economic criteria,
00:22:33.300 --> 00:22:37.200
and maybe by further refining those transmission planning
00:22:37.200 --> 00:22:40.110
criteria is that will help us as we move forward
00:22:40.110 --> 00:22:43.590
in evaluating the CCN applications with a tighter lens
00:22:43.590 --> 00:22:46.560
and CCN applications and settlement agreements
00:22:46.560 --> 00:22:48.000
with the tighter lens in the future.
00:22:48.000 --> 00:22:49.590
Right.
00:22:49.590 --> 00:22:52.770
Again, I would say that these are cost estimates.
00:22:52.770 --> 00:22:54.870
We don't know what the end cost will be.
00:22:54.870 --> 00:22:57.630
It could be more, and it could be less depending upon
00:22:57.630 --> 00:22:59.070
a lot of factors.
00:22:59.070 --> 00:23:00.960
Likely in this day and age, it's gonna be more
00:23:00.960 --> 00:23:03.480
with commodity and labor prices high.
00:23:03.480 --> 00:23:05.340
Sure.
Financing costs high.
00:23:05.340 --> 00:23:09.510
So it may be higher than the 2 million,
00:23:09.510 --> 00:23:12.330
but the other line, Route 54 may be higher
00:23:12.330 --> 00:23:14.253
than the initial proposed.
00:23:17.640 --> 00:23:18.930
Amount as well.
Yeah.
00:23:18.930 --> 00:23:21.420
So I think we just, we don't know.
00:23:21.420 --> 00:23:22.860
We have to go with this process
00:23:22.860 --> 00:23:24.603
that's been laid out before us.
00:23:27.030 --> 00:23:30.300
I think there's a band of reasonableness here where we ought
00:23:30.300 --> 00:23:34.710
to go ahead and accept this settlement and go forward.
00:23:34.710 --> 00:23:39.210
Well, certainly here, all the points,
00:23:39.210 --> 00:23:40.980
that Commissioner MCAdams,
00:23:40.980 --> 00:23:42.930
I'll help rattle the cage with you.
00:23:42.930 --> 00:23:47.930
Our job is to provide reliability at a reasonable cost.
00:23:47.970 --> 00:23:50.550
And certainly there benefits to doing things sooner
00:23:50.550 --> 00:23:52.290
rather than later with settlement uncertainty
00:23:52.290 --> 00:23:55.230
and commodity prices, construction availability.
00:23:55.230 --> 00:23:57.690
And certainly here are all concede the points
00:23:57.690 --> 00:23:58.523
that you've laid out.
00:23:58.523 --> 00:24:01.170
That sooner, getting connected sooner rather than later
00:24:01.170 --> 00:24:02.133
is always better.
00:24:03.498 --> 00:24:04.331
And the only, and,
00:24:04.331 --> 00:24:08.433
but we can't have uncontrolled costs
00:24:09.570 --> 00:24:12.000
just because parties agree.
00:24:12.000 --> 00:24:15.780
And I'd certainly say when we asked for folks to show
00:24:15.780 --> 00:24:18.000
their homework and show the calculus
00:24:18.000 --> 00:24:23.000
behind their thinking, what we saw here was not a lot.
00:24:25.080 --> 00:24:28.530
Just because we kind of, don't sort of don't want it
00:24:28.530 --> 00:24:33.530
to go this way is not very compelling in my mind.
00:24:35.250 --> 00:24:40.250
But the only thing and to the cage rattling going forward,
00:24:42.123 --> 00:24:46.163
I mean, costs are a key concern and there's a band,
00:24:48.720 --> 00:24:50.580
but it's pretty tight.
00:24:50.580 --> 00:24:55.580
And so going forward costs will always be a concern.
00:24:55.590 --> 00:24:59.040
And I think that's something that is philosophically shared
00:24:59.040 --> 00:25:00.780
amongst all of you.
00:25:00.780 --> 00:25:05.780
And we will need to see good reason for route changes
00:25:08.160 --> 00:25:09.240
and cost increases
00:25:09.240 --> 00:25:11.940
that are part of any settlement like this.
00:25:11.940 --> 00:25:16.940
The only thing that tips the scale for me
00:25:17.670 --> 00:25:21.690
in this case is getting those 200 some on megawatts on.
00:25:21.690 --> 00:25:22.523
As quickly as possible.
00:25:22.523 --> 00:25:26.220
As quickly as we can in a four, six, nine month delay.
00:25:26.220 --> 00:25:27.053
I hear you.
00:25:27.053 --> 00:25:29.280
And if it means that they can be plugged in
00:25:29.280 --> 00:25:33.510
for next summer, in the absence of 1281,
00:25:33.510 --> 00:25:37.980
we're making an implementation that that's the only thing
00:25:37.980 --> 00:25:41.490
that tips the scale to get this done sooner
00:25:41.490 --> 00:25:42.390
rather than later.
00:25:43.320 --> 00:25:47.700
Once we do get 1281 implemented and the rule making done,
00:25:47.700 --> 00:25:52.620
I think that's a reset and cost and credible calculus
00:25:52.620 --> 00:25:55.530
on why those costs are justified.
00:25:55.530 --> 00:25:59.040
I think we'll always need to be a principle
00:25:59.040 --> 00:26:00.300
that we look closely at.
00:26:00.300 --> 00:26:02.610
Okay, I'll respect the will of the body and support it.
00:26:02.610 --> 00:26:03.600
I agree with you, Mr. Chairman.
00:26:03.600 --> 00:26:08.190
Timeliness of completion of the project is important.
00:26:08.190 --> 00:26:12.120
And, but if these settlements keep coming up, I mean,
00:26:12.120 --> 00:26:14.460
we're gonna see a trend and--
00:26:14.460 --> 00:26:15.930
I'm there with you.
Yeah.
00:26:15.930 --> 00:26:18.600
Mr. Chairman, if you don't mind, let me take a second.
00:26:18.600 --> 00:26:23.040
I spent a little bit of time looking at the transmission
00:26:23.040 --> 00:26:25.860
construction reports that are required to be filed
00:26:25.860 --> 00:26:27.933
with the Commission on existing lines.
00:26:28.830 --> 00:26:31.620
I have found that many of them are incomplete.
00:26:31.620 --> 00:26:33.570
The lines have been completed,
00:26:33.570 --> 00:26:36.750
but the final registration of their costs have not.
00:26:36.750 --> 00:26:38.910
And I've spoken to some utilities about this,
00:26:38.910 --> 00:26:41.310
but it's my hope that they can go back
00:26:41.310 --> 00:26:42.630
and redouble their efforts,
00:26:42.630 --> 00:26:44.640
make sure those filings are up-to-date
00:26:44.640 --> 00:26:47.100
so that we do have a good basis for looking at these
00:26:47.100 --> 00:26:49.890
and seeing if they are over or under and have a good,
00:26:49.890 --> 00:26:52.500
maybe that helps us set a band of reasonableness.
00:26:52.500 --> 00:26:55.350
But without that, we really don't have a--
00:26:55.350 --> 00:26:57.240
Guiding story.
A guidance document.
00:26:57.240 --> 00:27:00.150
So it would be great for them to look at those.
00:27:00.150 --> 00:27:04.740
I've talked to staff about it and hopefully this will send
00:27:04.740 --> 00:27:06.750
the message to make sure that if you haven't
00:27:06.750 --> 00:27:11.750
put in your final construction costs work to do so.
00:27:13.080 --> 00:27:14.580
Great point Commissioner Gloftfelty.
00:27:14.580 --> 00:27:17.700
And I think having those updated cost estimates where,
00:27:17.700 --> 00:27:20.850
in those reports would be helpful because that would capture
00:27:20.850 --> 00:27:24.540
current data on the costs that the PDUs are experiencing,
00:27:24.540 --> 00:27:29.340
taking into considerate supply chain issues, inflation,
00:27:29.340 --> 00:27:32.940
and those factors that would impact cost.
00:27:32.940 --> 00:27:35.010
So I think it's important as we look,
00:27:35.010 --> 00:27:38.547
as we create a band in the future as to evaluate BCC
00:27:38.547 --> 00:27:42.120
and application settlement agreements that we take those
00:27:42.120 --> 00:27:44.613
very important real factors into consideration.
00:27:45.720 --> 00:27:46.737
Yeah, very good point.
00:27:46.737 --> 00:27:49.113
And I trust you'll stay on top of it.
00:27:49.113 --> 00:27:49.946
Yes, sir.
00:27:49.946 --> 00:27:54.123
Please bring your, as we go through these.
00:27:56.130 --> 00:28:01.130
Please do at periodic points,
00:28:01.320 --> 00:28:04.770
come back in these meetings and provide us updates
00:28:04.770 --> 00:28:06.384
on that initiative.
Absolutely.
00:28:06.384 --> 00:28:07.384
Thank you.
00:28:08.793 --> 00:28:12.090
That being said, do we have a motion?
00:28:12.090 --> 00:28:12.923
I would.
I will.
00:28:12.923 --> 00:28:16.110
One thing I think we do need to, if we are gonna approve,
00:28:16.110 --> 00:28:16.943
do we...
00:28:18.060 --> 00:28:19.080
Little bit of cleanup I think.
00:28:19.080 --> 00:28:21.330
Little cleanup on a finding of fact.
00:28:21.330 --> 00:28:22.290
Yes.
00:28:22.290 --> 00:28:25.710
So if we're approving the proposed order,
00:28:25.710 --> 00:28:27.880
we need to delete finding a fact 148
00:28:29.160 --> 00:28:34.160
and that finding of fact addresses Oncor's letter agreement
00:28:34.650 --> 00:28:38.850
with staff in the Texas Parks and Wildlife Department,
00:28:38.850 --> 00:28:43.850
and it provides some verbiage regarding that letter.
00:28:44.700 --> 00:28:46.590
And I don't think it's necessary.
00:28:46.590 --> 00:28:48.150
There's no reason for the Commission to speak
00:28:48.150 --> 00:28:50.070
to the appropriateness of a letter agreement
00:28:50.070 --> 00:28:50.903
with a non-party.
00:28:50.903 --> 00:28:53.820
So I don't think we can remove that as being unnecessary
00:28:53.820 --> 00:28:56.400
in the order and also add a new finding of fact
00:28:56.400 --> 00:28:59.580
that reflects that the party submitted additional evidence
00:28:59.580 --> 00:29:03.270
to support the party settlement agreement consistent
00:29:03.270 --> 00:29:06.510
with the Commission's direction at the May 26th open meeting
00:29:06.510 --> 00:29:07.473
and remand order.
00:29:10.110 --> 00:29:12.600
And adopt change is proposed by Commission council's memo.
00:29:12.600 --> 00:29:13.950
That's a motion.
00:29:13.950 --> 00:29:14.800
Yes.
Second.
00:29:16.410 --> 00:29:17.243
All in favor, say aye.
00:29:17.243 --> 00:29:18.076
Aye.
Aye.
00:29:19.080 --> 00:29:21.630
None opposed, motion passes.
00:29:21.630 --> 00:29:23.080
Thank y'all, good discussion.
00:29:24.030 --> 00:29:26.643
Good cage rattle.
We'll see.
00:29:29.691 --> 00:29:31.290
Well, we're gonna stay on top of that.
00:29:31.290 --> 00:29:33.210
Next item please, sir.
00:29:33.210 --> 00:29:36.600
Item 20 is Docket 52992.
00:29:36.600 --> 00:29:41.320
Petition to revoke RES Nation, LLC's Broker Registration
00:29:42.210 --> 00:29:45.723
Before you is a proposed default order filed on March 14th.
00:29:48.780 --> 00:29:50.133
Thoughts, comments.
00:29:56.310 --> 00:29:57.990
I think--
Oh yeah.
00:29:57.990 --> 00:30:00.600
I would propose moving forward with approving the ALJ's
00:30:00.600 --> 00:30:03.090
proposed default order and revoking resignations,
00:30:03.090 --> 00:30:05.670
Broker Registration and failure to amend their registration
00:30:05.670 --> 00:30:08.193
and failure to respond to client complaints.
00:30:10.890 --> 00:30:12.040
Agreement.
Me too.
00:30:12.990 --> 00:30:15.210
Is there a motion?
Yes.
00:30:15.210 --> 00:30:17.010
And I would second.
00:30:17.010 --> 00:30:17.843
Motion to second.
00:30:17.843 --> 00:30:18.676
All in favor, say aye.
00:30:18.676 --> 00:30:19.509
Aye.
Aye.
00:30:19.509 --> 00:30:20.880
None opposed.
00:30:20.880 --> 00:30:22.440
Next to item, please, sir.
00:30:22.440 --> 00:30:25.410
Item 21 is Docket 53377.
00:30:25.410 --> 00:30:27.600
Complaint of Engie Energy Marketing
00:30:27.600 --> 00:30:30.630
and Viridity Energy Solutions against Hrncir.
00:30:30.630 --> 00:30:32.550
before you is appeal of order number five,
00:30:32.550 --> 00:30:33.783
filed on March 18th.
00:30:36.810 --> 00:30:37.643
Another tricky one.
00:30:37.643 --> 00:30:39.393
Thoughts, comments.
00:30:40.920 --> 00:30:45.723
More questions about details.
00:30:48.960 --> 00:30:53.340
I certainly think there's what we've got in House leaves
00:30:53.340 --> 00:30:57.963
something to be desired in terms of the,
00:30:59.370 --> 00:31:01.683
whether this is administratively complete.
00:31:05.130 --> 00:31:06.360
The...
00:31:06.360 --> 00:31:07.860
Yeah, I would agree.
00:31:07.860 --> 00:31:09.990
I mean, I think this is one of those,
00:31:09.990 --> 00:31:14.990
when you dig to the filing, you have to listen to staff
00:31:15.240 --> 00:31:18.750
on some of these things that they're the ones who can decide
00:31:18.750 --> 00:31:21.633
whether they're administratively complete or not.
00:31:23.456 --> 00:31:27.240
And it seems to me that there are some areas
00:31:27.240 --> 00:31:31.080
where they are not complete and staff has highlighted those.
00:31:31.080 --> 00:31:36.080
And it would seem to me that it would be a instead of, well,
00:31:37.770 --> 00:31:41.040
we should overturn the ALJs and ask for additional
00:31:41.040 --> 00:31:43.830
information to ensure that this docket
00:31:43.830 --> 00:31:45.750
can be administratively complete.
00:31:45.750 --> 00:31:48.270
This has nothing to do with the validity of the document,
00:31:48.270 --> 00:31:52.350
of the dispute it has to do with the completeness
00:31:52.350 --> 00:31:54.330
of the application.
00:31:54.330 --> 00:31:56.820
Yeah, we've got a rule that sets standard of what needs
00:31:56.820 --> 00:32:00.870
to be provided and blanket affidavits
00:32:00.870 --> 00:32:03.780
and kind of shorthand work.
00:32:03.780 --> 00:32:07.290
Doesn't seem to, does not pass the bar in my mind
00:32:07.290 --> 00:32:12.090
and we need to see more detailed nature and contents
00:32:12.090 --> 00:32:14.583
of the evidence that's in question.
00:32:15.900 --> 00:32:19.080
So I think this case presents us with a policy issue
00:32:19.080 --> 00:32:21.780
of about trying to strike a balance between the Commission's
00:32:21.780 --> 00:32:24.900
efficient resolution and formal complaints by mark
00:32:24.900 --> 00:32:28.480
participants, stakeholders against Hrncir versus applying
00:32:31.020 --> 00:32:35.580
the requirements in 22251 that apply to formal complaints
00:32:35.580 --> 00:32:36.960
against Hrncir, right.
00:32:36.960 --> 00:32:39.780
In one hand, you wanna make sure that you get all
00:32:39.780 --> 00:32:42.780
the information according to the requirements,
00:32:42.780 --> 00:32:45.960
to be able to efficiently resolve these complaints
00:32:45.960 --> 00:32:46.860
at the Commission.
00:32:47.794 --> 00:32:49.740
And on the other hand, you don't want to,
00:32:49.740 --> 00:32:53.040
you gotta read the rule and you gotta make sure that we're
00:32:53.040 --> 00:32:54.840
not being overly restrictive to the point
00:32:54.840 --> 00:32:57.960
where we're requiring trial on paper up front
00:32:57.960 --> 00:32:59.490
in the entire evidentiary record.
00:32:59.490 --> 00:33:02.460
I mean, discovery plays a role in these,
00:33:02.460 --> 00:33:04.110
in contested case proceedings.
00:33:04.110 --> 00:33:05.550
And if you read the rule, I mean,
00:33:05.550 --> 00:33:10.550
I think staff brings up three main points where they found
00:33:11.730 --> 00:33:15.060
that the complaint was deficient.
00:33:15.060 --> 00:33:18.240
And I'll start with the affidavits.
00:33:18.240 --> 00:33:20.370
I think they were deficient.
00:33:20.370 --> 00:33:25.370
I think NG's supplemental affidavit is sufficient
00:33:26.400 --> 00:33:28.050
at this time.
00:33:28.050 --> 00:33:30.870
They did come back and include a whole lot more information,
00:33:30.870 --> 00:33:33.360
that's consistent with other affidavits that have been filed
00:33:33.360 --> 00:33:36.750
in complaints against Hrncir in prior cases.
00:33:36.750 --> 00:33:41.160
And so, I think Viridity would have to come back
00:33:41.160 --> 00:33:45.450
and file affidavit that con consists of that type
00:33:45.450 --> 00:33:49.410
of information for us to be able to find it sufficient.
00:33:49.410 --> 00:33:52.740
With respect to the prong on or the requirement
00:33:52.740 --> 00:33:54.600
that the complaint contains a concise statement
00:33:54.600 --> 00:33:56.880
without argument of pertinent facts,
00:33:56.880 --> 00:33:58.653
a record would, a record was,
00:33:59.580 --> 00:34:01.860
you have to provide a, each fact has to be supported
00:34:01.860 --> 00:34:03.930
by a reference to the record if any.
00:34:03.930 --> 00:34:08.610
I think the, if any portion of it provides some flexibility
00:34:08.610 --> 00:34:13.200
to be able to obtain those facts
00:34:13.200 --> 00:34:16.170
through the complaint contestive case process.
00:34:16.170 --> 00:34:19.443
And that's the rule of targeted discovery.
00:34:20.910 --> 00:34:23.940
I know that the 104 page complaint does contain some
00:34:23.940 --> 00:34:24.773
arguments in there,
00:34:24.773 --> 00:34:29.720
but I think these are complicated matters
00:34:30.600 --> 00:34:34.890
and sometimes a concise statement is,
00:34:34.890 --> 00:34:36.570
could be a very long statement when it comes down
00:34:36.570 --> 00:34:38.430
to ERCOT technical matters.
00:34:38.430 --> 00:34:42.870
So I think with respect to the first prong of,
00:34:42.870 --> 00:34:46.980
or this first requirement under 22251D,
00:34:46.980 --> 00:34:49.020
I would be interested in getting your thoughts on that
00:34:49.020 --> 00:34:54.020
because I don't, you can read it in one way of requiring
00:34:54.060 --> 00:34:58.530
that each fact is supported by reference to the record.
00:34:58.530 --> 00:35:01.950
If any, but that if any words matter, and that if any,
00:35:01.950 --> 00:35:06.950
in my mind provides some flexibility to be able to support
00:35:07.155 --> 00:35:11.193
it later through discovery.
00:35:12.030 --> 00:35:14.460
With respect to the second requirement,
00:35:14.460 --> 00:35:16.740
a record consisting of a certified or sworn copy
00:35:16.740 --> 00:35:19.140
of any document constituting or evidence
00:35:19.140 --> 00:35:22.230
in the matter complained of, the record may also continue
00:35:22.230 --> 00:35:24.300
any other item heard into the issues or points presented
00:35:24.300 --> 00:35:27.420
for review, including affidavits or other evidence
00:35:27.420 --> 00:35:29.103
on which a complaint relies.
00:35:30.900 --> 00:35:35.900
I think we don't know what Viridity and NG has.
00:35:36.390 --> 00:35:38.100
We can't just assume they had the information,
00:35:38.100 --> 00:35:41.043
didn't provide it to us, is what I'm thinking.
00:35:42.360 --> 00:35:43.620
They get, they have,
00:35:43.620 --> 00:35:46.110
they need to give us everything they have up front.
00:35:46.110 --> 00:35:48.900
But again, that is the role of discovery
00:35:48.900 --> 00:35:52.140
is to get additional information in the record.
00:35:52.140 --> 00:35:55.650
So I'm interested in hearing your thoughts
00:35:55.650 --> 00:35:56.910
on these two requirements.
00:35:56.910 --> 00:35:59.670
I think we're on the affidavit.
00:35:59.670 --> 00:36:04.470
I think the supplemental affidavit from NG obviously
00:36:04.470 --> 00:36:06.780
is sufficient and Viridity is continues not to be,
00:36:06.780 --> 00:36:08.580
but that's only one piece of the requirement
00:36:08.580 --> 00:36:10.500
and obviously would require some action there.
00:36:10.500 --> 00:36:14.550
But the other two requirements under the procedural role
00:36:14.550 --> 00:36:17.070
in my mind, I think is worth having a discussion about,
00:36:17.070 --> 00:36:21.150
because again, while we have a formal,
00:36:21.150 --> 00:36:24.060
a rule that addresses formal complaints against our ERCOT,
00:36:24.060 --> 00:36:26.010
that's different from our general complaint rule,
00:36:26.010 --> 00:36:26.880
it's for a reason.
00:36:26.880 --> 00:36:28.470
But at the same time,
00:36:28.470 --> 00:36:33.400
we must ensure that market participants and stakeholders
00:36:34.500 --> 00:36:38.850
have an opportunity, which they will to file a complaint
00:36:38.850 --> 00:36:43.850
against ERCOT on matters that have been addressed
00:36:43.867 --> 00:36:46.233
through a ERCOT action, whether ADR or not.
00:36:48.270 --> 00:36:50.970
And be able to give us everything they have up front,
00:36:50.970 --> 00:36:53.550
but not continue to kick these complaints back
00:36:53.550 --> 00:36:55.170
because they didn't meet everything to the team.
00:36:55.170 --> 00:36:56.940
I mean, that's the whole role of discovery
00:36:56.940 --> 00:36:58.590
in a contested case process.
00:36:58.590 --> 00:37:00.180
Sure, I don't think anybody wants to kick
00:37:00.180 --> 00:37:01.983
the complaints back endlessly.
00:37:04.348 --> 00:37:06.090
I do think we've got the rule established a hurdle
00:37:06.090 --> 00:37:07.500
that needs to be met.
00:37:07.500 --> 00:37:09.870
And to your point of if NG and Viridity
00:37:09.870 --> 00:37:12.240
don't have that information, they need to tell us
00:37:13.470 --> 00:37:18.330
rather than just kind of a leaving it open to question.
00:37:18.330 --> 00:37:19.980
Mr. Chairman.
Yes sir.
00:37:19.980 --> 00:37:20.813
I totally agree.
00:37:20.813 --> 00:37:22.050
If they don't have it, they don't have it,
00:37:22.050 --> 00:37:25.080
but my reading of their responses complaint is that
00:37:25.080 --> 00:37:28.023
it's their option whether they provide it or not.
00:37:29.670 --> 00:37:31.004
So...
00:37:31.004 --> 00:37:32.093
And it's a question of when.
00:37:34.350 --> 00:37:36.870
So on that Commissioner,
00:37:36.870 --> 00:37:41.440
it sounds like we believe there's daylight
00:37:43.350 --> 00:37:45.090
in terms of the first issue
00:37:45.090 --> 00:37:47.733
of granting appeal, staff's appeal.
00:37:49.650 --> 00:37:54.000
We believe that there's there's room to be filled in
00:37:54.000 --> 00:37:58.590
by the complainants, to better establish the record.
00:37:58.590 --> 00:37:59.913
So first hurdle, right.
00:38:01.500 --> 00:38:02.760
Which grant the appeal.
Yes, sir.
00:38:02.760 --> 00:38:04.460
To grant the appeal.
Yes or no?
00:38:05.545 --> 00:38:06.870
What I'm hearing is in some version.
00:38:06.870 --> 00:38:09.960
Yes, but it's what, when you grant the appeal,
00:38:09.960 --> 00:38:14.380
what instruction is sent back down to fill out
00:38:15.300 --> 00:38:18.483
the evidentiary record for that stage of the process?
00:38:19.980 --> 00:38:23.580
Correct, I mean, we're trying to provide as detailed
00:38:23.580 --> 00:38:24.780
a guidance as possible.
00:38:24.780 --> 00:38:27.090
In my view, this is incredibly important.
00:38:27.090 --> 00:38:30.197
This is good that we're hammering this out now,
00:38:30.197 --> 00:38:32.700
'cause I believe there has to be a mechanism.
00:38:32.700 --> 00:38:36.210
There's a legal requirement for a mechanism to exist
00:38:36.210 --> 00:38:38.850
for complaints, for some type of appellate review
00:38:38.850 --> 00:38:40.200
by the Commission.
00:38:40.200 --> 00:38:44.220
So, and we haven't had to exercise that to a great deal
00:38:44.220 --> 00:38:48.693
at the Commission until now because of our newfound,
00:38:50.010 --> 00:38:52.653
statutory and legislative emphasis on our oversight.
00:38:54.000 --> 00:38:57.510
But this is kind of a stage where we're acting
00:38:57.510 --> 00:38:58.950
as the grand jury here.
00:38:58.950 --> 00:39:01.800
We're trying to determine if there's enough evidence
00:39:01.800 --> 00:39:06.800
to proceed with that next stage of the investigative process
00:39:07.380 --> 00:39:09.183
and the appellate process.
00:39:10.050 --> 00:39:15.050
So I believe there's enough to grant the appeal of staff.
00:39:15.810 --> 00:39:17.730
There's enough daylight there.
00:39:17.730 --> 00:39:21.480
Now, if you wanna impose your targets
00:39:21.480 --> 00:39:23.370
on what they further owe,
00:39:23.370 --> 00:39:26.610
absolutely, I think you've got sound arguments there,
00:39:26.610 --> 00:39:29.340
but it needs to go back, correct?
00:39:29.340 --> 00:39:31.890
Yeah, it needs to go back.
00:39:31.890 --> 00:39:34.020
I mean, if nothing else, but on the affidavits,
00:39:34.020 --> 00:39:34.853
like you said.
00:39:34.853 --> 00:39:37.530
Sure, I mean, and but yes.
00:39:37.530 --> 00:39:40.410
I think that we need to make sure that we get
00:39:40.410 --> 00:39:44.340
the information we need to efficiently resolve this case.
00:39:44.340 --> 00:39:45.570
I think we're all on the same page here.
00:39:45.570 --> 00:39:46.980
Yep. Okay.
00:39:46.980 --> 00:39:49.863
What I'm trying to address here is,
00:39:51.030 --> 00:39:52.890
or trying to provide here some kind of guidance
00:39:52.890 --> 00:39:57.890
to the parties so that they know what our expectations are
00:39:58.470 --> 00:40:00.420
with respect to filing complaints and what they need
00:40:00.420 --> 00:40:04.410
to go back and fill in their complaint.
00:40:04.410 --> 00:40:09.120
And also discuss from a policy standpoint,
00:40:09.120 --> 00:40:11.270
what, how do we want to interpret this rule
00:40:12.810 --> 00:40:17.310
to where we provide an efficient path for stakeholders,
00:40:17.310 --> 00:40:20.100
mark participants to file a complaint,
00:40:20.100 --> 00:40:22.353
but not overly restricted to the point where,
00:40:23.850 --> 00:40:28.260
having them litigate this case by trial on paper up front,
00:40:28.260 --> 00:40:29.250
because that's just not the way
00:40:29.250 --> 00:40:31.710
contested case proceedings work.
00:40:31.710 --> 00:40:32.543
Absolutely.
00:40:32.543 --> 00:40:33.810
Complaints applications are filed.
00:40:33.810 --> 00:40:35.850
And the case in the evidentiary record is developed
00:40:35.850 --> 00:40:38.730
throughout the entire case through discovery.
00:40:38.730 --> 00:40:42.240
And we can't expect them to just give us everything up front
00:40:42.240 --> 00:40:45.390
and discovery plays a role.
00:40:45.390 --> 00:40:50.363
And so as I read through sort of the read the requirements,
00:40:50.363 --> 00:40:52.770
I mean, there's definitely deficiencies here and there,
00:40:52.770 --> 00:40:54.840
but how do we want to address this?
00:40:54.840 --> 00:40:55.980
Because so ALJ,
00:40:55.980 --> 00:40:58.280
I think put us kind of in an awkward position.
00:40:59.220 --> 00:41:03.120
The order says sufficiently administrative complete,
00:41:03.120 --> 00:41:06.420
well mean it's--
Subjective threshold.
00:41:06.420 --> 00:41:07.410
It's subjective.
00:41:07.410 --> 00:41:11.219
Well, and I think we could also strike a balance between
00:41:11.219 --> 00:41:14.670
providing some guidance from the dais
00:41:14.670 --> 00:41:17.160
and not leaving things just wide open without,
00:41:17.160 --> 00:41:19.020
but striking balance between providing guidance,
00:41:19.020 --> 00:41:20.720
without being overly prescriptive.
00:41:21.570 --> 00:41:25.110
As always, whether it's this docket or routing docket
00:41:25.110 --> 00:41:29.460
or anything else, I think we would all welcome stakeholders
00:41:29.460 --> 00:41:31.623
to go above and beyond.
00:41:32.880 --> 00:41:35.970
They don't always give us what we need.
00:41:35.970 --> 00:41:37.733
And so even without specific guidance,
00:41:37.733 --> 00:41:40.033
I think you're giving some guidance right now.
00:41:41.790 --> 00:41:44.370
These folks should feel free to go above and beyond
00:41:44.370 --> 00:41:45.723
what the bare minimum is.
00:41:46.890 --> 00:41:50.550
That in any docket can make life a lot easier
00:41:50.550 --> 00:41:52.530
for everybody involved.
00:41:52.530 --> 00:41:55.990
So I think, I mean, I think we would all appreciate
00:41:58.110 --> 00:42:02.430
any in all stakeholders providing more rather than less,
00:42:02.430 --> 00:42:03.990
if they've got it.
00:42:03.990 --> 00:42:07.500
I think we all, what I'm hearing is that we know we need
00:42:07.500 --> 00:42:08.500
to grant the appeal.
00:42:09.900 --> 00:42:11.823
You've provided some good guidance,
00:42:12.810 --> 00:42:16.620
but I'd also say we welcome both of these complainants
00:42:16.620 --> 00:42:19.620
to feel free to go above and beyond what the bare minimum
00:42:19.620 --> 00:42:22.570
and the rule is so that we can move forward with this case.
00:42:24.326 --> 00:42:25.740
I agree with your points.
00:42:25.740 --> 00:42:28.920
I think ultimately providing guidance,
00:42:28.920 --> 00:42:31.620
having this complaint come back because we need to resolve
00:42:31.620 --> 00:42:34.020
this issue in some form of fashion.
00:42:34.020 --> 00:42:36.300
So there isn't any uncertainty out there with respect
00:42:36.300 --> 00:42:39.120
to load resource participation in a very important,
00:42:39.120 --> 00:42:41.460
responsive reserve service for our ERCOT.
00:42:41.460 --> 00:42:43.470
You bet, I mean, I wanna see this come back.
00:42:43.470 --> 00:42:46.440
I mean, in the values are large enough.
00:42:46.440 --> 00:42:48.570
We need to try to process this.
00:42:48.570 --> 00:42:49.860
Everybody wants this to move forward.
00:42:49.860 --> 00:42:50.693
Yeah.
00:42:53.100 --> 00:42:55.380
So I think is we are looking for a motion
00:42:55.380 --> 00:42:56.583
to grant the appeal.
00:43:00.480 --> 00:43:01.890
Anybody got--
So moved.
00:43:01.890 --> 00:43:02.723
Second.
00:43:04.470 --> 00:43:05.303
All in favor, say aye.
00:43:05.303 --> 00:43:06.720
Aye.
Aye.
00:43:06.720 --> 00:43:07.950
None opposed.
00:43:07.950 --> 00:43:09.700
Give everything you need Mr. Jenay.
00:43:12.990 --> 00:43:14.270
Well, I'm...
00:43:16.620 --> 00:43:18.390
Y'all have given a little bit of guidance,
00:43:18.390 --> 00:43:22.570
staff made particulars in their appeal
00:43:23.700 --> 00:43:25.050
of what was deficient.
00:43:25.050 --> 00:43:27.780
I'm not sure I'm hearing settle total agreement
00:43:27.780 --> 00:43:31.583
with that position and perhaps we need to hedge
00:43:34.830 --> 00:43:39.830
in grant the appeal to the extent it's consistent
00:43:39.870 --> 00:43:42.060
with y'all's discussion here.
00:43:42.060 --> 00:43:45.300
'Cause I think there's a little bit of daylight between
00:43:45.300 --> 00:43:46.410
the two positions.
00:43:46.410 --> 00:43:51.410
Well, I trust both these companies will do everything
00:43:52.740 --> 00:43:56.340
in their effort to take the above and beyond approach
00:43:56.340 --> 00:43:59.970
rather than just the bare minimum perhaps.
00:43:59.970 --> 00:44:02.701
Yeah, I've never been called an optimist.
00:44:02.701 --> 00:44:04.830
(all laugh)
00:44:04.830 --> 00:44:07.550
All right, we'll be keeping a close eye
00:44:07.550 --> 00:44:08.853
on both these entities.
00:44:12.300 --> 00:44:14.376
It's a process, t's not a pretty one.
00:44:14.376 --> 00:44:15.963
This is the start of it.
00:44:17.340 --> 00:44:19.090
All right, next item please, sir.
00:44:23.100 --> 00:44:27.123
Next item is 22, Docket 53442.
00:44:27.990 --> 00:44:32.990
Before you use a revised draft order filed on June 28th,
00:44:33.270 --> 00:44:35.580
Commissioner Cobos has a memo on this matter.
00:44:35.580 --> 00:44:36.810
Thank you, sir.
00:44:36.810 --> 00:44:39.690
Commissioner Cobos, would you lay out your memo for us?
00:44:39.690 --> 00:44:43.620
Yes, so my memo, I think is straightforward.
00:44:43.620 --> 00:44:48.300
When we addressed this case at the May 26th open meeting,
00:44:48.300 --> 00:44:51.870
we made a decision that was specifically related
00:44:51.870 --> 00:44:55.140
to 39918, subsection B1,
00:44:55.140 --> 00:44:57.270
which relates to the leasing operating
00:44:57.270 --> 00:45:00.390
of mobile generation costs.
00:45:00.390 --> 00:45:03.870
And as I read the draft order, the draft order expanded
00:45:03.870 --> 00:45:08.870
into another provision where that related to the ownership,
00:45:09.240 --> 00:45:10.830
procurement and operation
00:45:10.830 --> 00:45:13.140
of transmission distribution facilities.
00:45:13.140 --> 00:45:15.780
That is, those are types of facilities that we did not
00:45:15.780 --> 00:45:18.900
address in our decision at the May 26th open meeting.
00:45:18.900 --> 00:45:20.490
And from my standpoint,
00:45:20.490 --> 00:45:22.780
I would prefer not to give policy guidance
00:45:23.661 --> 00:45:26.550
on a statutory provision that was not addressed as part of
00:45:26.550 --> 00:45:31.470
our decision at the open meeting and defer to the rulemaking
00:45:31.470 --> 00:45:35.373
proceeding that will be open to implement House Bill 2483,
00:45:37.050 --> 00:45:40.290
to provide further guidance on that statutory provision
00:45:40.290 --> 00:45:43.410
and limit the draft order to the specific statutory
00:45:43.410 --> 00:45:48.030
provision 399181 that we addressed in our decision.
00:45:48.030 --> 00:45:52.140
And so my modifications to the order were intended to remove
00:45:52.140 --> 00:45:55.740
the references to subsection B2,
00:45:55.740 --> 00:45:58.020
that were not addressed by our decision.
00:45:58.020 --> 00:46:02.880
And then also to remove the references of energy restoration
00:46:02.880 --> 00:46:05.700
costs and replace them with the statutory language,
00:46:05.700 --> 00:46:08.970
appropriate statutory language in references that are used
00:46:08.970 --> 00:46:13.545
to relate to, that are used to refer to mobile generation
00:46:13.545 --> 00:46:16.027
in subsection 39 of B1.
B1.
00:46:16.990 --> 00:46:21.990
Yeah, I'm okay amending the draft order
00:46:22.260 --> 00:46:24.540
on the technical points you've made,
00:46:24.540 --> 00:46:27.333
but I do want to be very clear that when we,
00:46:28.667 --> 00:46:32.970
that I do believe that the statute is clear that long lead
00:46:32.970 --> 00:46:37.290
time facilities are included in this kind of recovery
00:46:37.290 --> 00:46:39.870
while it's not addressed in this draft order.
00:46:39.870 --> 00:46:43.290
Those long lead time items are absolutely critical
00:46:43.290 --> 00:46:46.770
for transmission system and reliability.
00:46:46.770 --> 00:46:49.050
And especially in this day and age,
00:46:49.050 --> 00:46:53.280
when we've got the supply chain issues that we've got
00:46:53.280 --> 00:46:56.280
and we're experiencing across the state, across the country.
00:46:57.180 --> 00:47:00.930
Long lead time items are even more important than ever
00:47:00.930 --> 00:47:03.480
to make sure we can keep the system reliable
00:47:03.480 --> 00:47:06.060
and we'll address that at the appropriate time.
00:47:06.060 --> 00:47:10.503
But that makes sense to amend this draft order,
00:47:11.610 --> 00:47:12.690
as you recommend.
00:47:12.690 --> 00:47:14.040
Other thoughts or comments.
00:47:15.360 --> 00:47:17.850
I kind of struggle with it just because we're separating
00:47:17.850 --> 00:47:20.550
two parts of this statute.
00:47:20.550 --> 00:47:25.140
And I don't know that it's a huge policy issue for us
00:47:25.140 --> 00:47:25.973
to decide here.
00:47:25.973 --> 00:47:29.830
So I'm happy to support your effort, but I just think that
00:47:32.190 --> 00:47:36.090
if we're gonna readdress this in a future rule,
00:47:36.090 --> 00:47:40.620
so the vast majority of those issues will be resolved then.
00:47:40.620 --> 00:47:44.580
Since this component of the law is not apparent
00:47:44.580 --> 00:47:47.883
in this case, it just seems like it's moot,
00:47:48.990 --> 00:47:51.270
therefore taking it out, doesn't do anything.
00:47:51.270 --> 00:47:53.190
But leaving it in, doesn't do anything either.
00:47:53.190 --> 00:47:56.220
So I'm not,
00:47:56.220 --> 00:47:58.770
I don't know where your legal thought process is on that,
00:47:58.770 --> 00:48:00.810
but I'd be interested in that.
00:48:00.810 --> 00:48:01.643
I mean--
00:48:01.643 --> 00:48:02.805
Happy to hear on the side of course.
00:48:02.805 --> 00:48:04.907
Yeah, subsection B2 was simply not addressed
00:48:04.907 --> 00:48:06.360
in the this contestant case.
00:48:06.360 --> 00:48:08.460
So it doesn't make sense to issue not to order
00:48:08.460 --> 00:48:11.280
addressing a statutory provision that was not part
00:48:11.280 --> 00:48:14.070
of center point's application and address in this case.
00:48:14.070 --> 00:48:18.327
Yeah, Commissioner, I'm happy with the revisions as well.
00:48:18.327 --> 00:48:20.970
And in respect your view on,
00:48:20.970 --> 00:48:22.890
since it was not in the original proceeding,
00:48:22.890 --> 00:48:24.420
let's leave that separate and apart.
00:48:24.420 --> 00:48:28.860
However, it appears the policy formulation process
00:48:28.860 --> 00:48:31.350
is heading in a direction on conforming
00:48:31.350 --> 00:48:33.624
both the long lead time facilities
00:48:33.624 --> 00:48:36.600
and this and harmonizing both.
00:48:36.600 --> 00:48:37.890
And I agree with the chairman's point
00:48:37.890 --> 00:48:41.283
that subsection B2 is a very important, statutory provision.
00:48:42.150 --> 00:48:45.090
And we will certainly address that provision
00:48:45.090 --> 00:48:46.230
in our rule making proceeding.
00:48:46.230 --> 00:48:49.620
And I think it's important ultimately in staff's project
00:48:49.620 --> 00:48:54.030
that they open that we, as we look to formulate a framework
00:48:54.030 --> 00:48:59.030
to address both sets of costs in both in subsection B1
00:48:59.790 --> 00:49:03.570
and B2, that's a perfect forum for us to create a framework
00:49:03.570 --> 00:49:05.860
to review both sets of costs
00:49:06.810 --> 00:49:09.363
through appropriate procedural process.
00:49:10.290 --> 00:49:12.210
Agreed.
Fair enough.
00:49:12.210 --> 00:49:13.323
Yep.
All right.
00:49:15.714 --> 00:49:18.900
Is there a motion to approve the draft order filed
00:49:18.900 --> 00:49:21.870
on June 29th as amended by Commissioner Cobos?
00:49:21.870 --> 00:49:25.380
I would so move since I've started this whole ball of wax
00:49:25.380 --> 00:49:27.303
and then happy to be joined.
00:49:28.230 --> 00:49:29.250
Second.
00:49:29.250 --> 00:49:30.210
All in favor, say aye.
00:49:30.210 --> 00:49:31.410
Aye.
Aye.
00:49:31.410 --> 00:49:33.960
None opposed, motion passes.
00:49:33.960 --> 00:49:35.073
Next item please, sir.
00:49:37.170 --> 00:49:39.450
Well, I think that brings us to 25.
00:49:39.450 --> 00:49:41.880
Commissioner MC Adams, do you have an update for us?
00:49:41.880 --> 00:49:42.840
I do, sir.
00:49:42.840 --> 00:49:45.360
And if you can hear me, I'll give you an update.
00:49:45.360 --> 00:49:48.150
And then I'd also like to open the door on another issue
00:49:48.150 --> 00:49:52.830
that has become apparent as a part of the overall DER policy
00:49:52.830 --> 00:49:55.590
framework that we're attempting to move forward on
00:49:55.590 --> 00:49:59.490
at the Commission and ERCOT and among our TDSPs.
00:49:59.490 --> 00:50:02.580
So given the direction of the last open meeting
00:50:02.580 --> 00:50:04.890
regarding the DER pilot project,
00:50:04.890 --> 00:50:07.380
I wanted to take this opportunity to brief you
00:50:07.380 --> 00:50:11.010
and the public on how I believe we should proceed
00:50:11.010 --> 00:50:14.280
in order to best accomplish the formation and implementation
00:50:14.280 --> 00:50:16.050
of such a pilot.
00:50:16.050 --> 00:50:20.400
In future, I will better reserve comments on this topic
00:50:20.400 --> 00:50:24.150
for docket number 51603.
00:50:24.150 --> 00:50:26.340
Since it is our DER docket,
00:50:26.340 --> 00:50:30.570
where responses were filed to our broad RFP
00:50:30.570 --> 00:50:34.353
on how to best avail ourselves of the resources.
00:50:35.280 --> 00:50:38.670
But right now I'll take it up in 52373.
00:50:38.670 --> 00:50:41.910
My staff and I over the last week have been engaging
00:50:41.910 --> 00:50:44.220
with stakeholders on how to best launch efforts
00:50:44.220 --> 00:50:47.010
around the project, the pilot,
00:50:47.010 --> 00:50:50.370
and I believe a three step plan should be considered
00:50:50.370 --> 00:50:52.020
by the Commission.
00:50:52.020 --> 00:50:55.870
Firstly, how to set the pilot up.
00:50:59.400 --> 00:51:03.390
I would propose forming a informal workshop,
00:51:03.390 --> 00:51:07.080
assembling a group of relevant stakeholders together
00:51:07.080 --> 00:51:12.080
here at the Commission on Monday, July 11th at 9:00 AM.
00:51:12.570 --> 00:51:14.460
Here in the Commissioner's hearing room,
00:51:14.460 --> 00:51:17.970
to consider key goals and objectives that we hope
00:51:17.970 --> 00:51:21.870
to accomplish through implementation of a proposed pilot.
00:51:21.870 --> 00:51:24.420
The workshop would also discuss issues to be determined by
00:51:24.420 --> 00:51:28.050
the Commission that we need to make decisions on
00:51:28.050 --> 00:51:29.460
in order to launch the pilot,
00:51:29.460 --> 00:51:32.340
which would include the scale of the project,
00:51:32.340 --> 00:51:34.950
the duration, the participation,
00:51:34.950 --> 00:51:36.390
the interchange of customers.
00:51:36.390 --> 00:51:41.390
Meaning if there is a network of retail providers or NOIs,
00:51:43.170 --> 00:51:45.660
that's availing themselves off the pilot,
00:51:45.660 --> 00:51:49.380
then how can customers move in between reps
00:51:49.380 --> 00:51:51.150
over the duration of that pilot?
00:51:51.150 --> 00:51:53.730
So that they're not locked in for a number of years
00:51:53.730 --> 00:51:55.170
under one particular plan,
00:51:55.170 --> 00:51:57.930
because that would make it unappealing to the broadest
00:51:57.930 --> 00:52:01.050
possible segment of customers.
00:52:01.050 --> 00:52:02.370
So we need to answer those questions.
00:52:02.370 --> 00:52:04.380
And then overall reliability.
00:52:04.380 --> 00:52:09.380
The operational interconnection and export dynamics
00:52:10.470 --> 00:52:13.983
that are sure to be observed, how do we overcome those?
00:52:14.940 --> 00:52:17.217
And then depending on the feedback from these stakeholders,
00:52:17.217 --> 00:52:19.860
Commissioner Gloftfelty and myself could organize
00:52:19.860 --> 00:52:24.780
a joint memorandum, capturing consensus positions on policy
00:52:24.780 --> 00:52:26.670
that could be addressed within the pilot.
00:52:26.670 --> 00:52:29.880
We could then take that up for discussion within the full
00:52:29.880 --> 00:52:33.880
Commission at our July 14th open meeting so that we could
00:52:35.610 --> 00:52:39.270
better give direction on what next steps are.
00:52:39.270 --> 00:52:43.470
The work group is by invitation only simply to make
00:52:43.470 --> 00:52:45.750
the numbers of participants manageable,
00:52:45.750 --> 00:52:49.110
given the breadth of the universe of potential stakeholders
00:52:49.110 --> 00:52:50.970
who could be involved.
00:52:50.970 --> 00:52:53.490
However, if members of the stakeholder community
00:52:53.490 --> 00:52:57.030
or the public would like to be considered for inclusion,
00:52:57.030 --> 00:53:00.600
they may reach out to my staff, which is Tiffany Woo,
00:53:00.600 --> 00:53:03.870
whose contact information may be found on my agency homepage
00:53:03.870 --> 00:53:04.703
on the website.
00:53:04.703 --> 00:53:08.160
I won't advertise her location and contact information.
00:53:08.160 --> 00:53:09.974
Somebody's gonna have to do some homework to find her,
00:53:09.974 --> 00:53:11.373
but it is possible.
00:53:13.890 --> 00:53:16.473
She's out here.
She is right there.
00:53:17.400 --> 00:53:22.400
Now as to the second step, a task force.
00:53:23.250 --> 00:53:26.820
The memo, I believe will the way we are currently
00:53:26.820 --> 00:53:29.850
envisioning this, we will articulate a belief that we need
00:53:29.850 --> 00:53:32.370
to form a task force in the near future,
00:53:32.370 --> 00:53:35.790
which would discuss and observe implementation of the pilot.
00:53:35.790 --> 00:53:38.580
This group would meet periodically to discuss
00:53:38.580 --> 00:53:41.280
operational obstacles that may present themselves
00:53:41.280 --> 00:53:43.170
as we head into one planning,
00:53:43.170 --> 00:53:47.610
but then two final implementation and help identify
00:53:47.610 --> 00:53:52.610
the Commission policy areas that we need to break down
00:53:52.650 --> 00:53:55.260
obstacles, make determinations and give instructions
00:53:55.260 --> 00:53:58.740
to both ERCOT, TDSP or stakeholders
00:53:58.740 --> 00:54:01.053
in order to ensure timely implementation.
00:54:02.130 --> 00:54:04.260
And then finally, Mr. Chairman, members,
00:54:04.260 --> 00:54:09.210
we also need to set a target implementation date or season.
00:54:09.210 --> 00:54:12.180
And obviously that would come, I believe through feedback
00:54:12.180 --> 00:54:15.540
from our stakeholders as a part of this workshop
00:54:15.540 --> 00:54:19.440
on what is achievable and that way the task force
00:54:19.440 --> 00:54:22.350
and the Commission and ERCOT working together
00:54:22.350 --> 00:54:25.383
can help hold us accountable to that implementation date.
00:54:27.600 --> 00:54:29.300
Sounds like a good path forward.
00:54:30.480 --> 00:54:32.790
I like your optimism that the first step
00:54:32.790 --> 00:54:35.340
will have all the questions scoped and answered
00:54:35.340 --> 00:54:37.023
by July 14th.
00:54:39.491 --> 00:54:41.673
We're wearing out horses Mr. Chairman.
00:54:42.570 --> 00:54:46.260
These will be the broad, high level questions that need
00:54:46.260 --> 00:54:51.030
to be answered simply to get this pretty massive project
00:54:51.030 --> 00:54:52.380
away from the dock,
00:54:52.380 --> 00:54:54.873
and then start moving toward our target.
00:54:56.250 --> 00:54:58.710
I was gonna say, as I had said before,
00:54:58.710 --> 00:55:00.720
I'm a believer in pilot projects as opposed
00:55:00.720 --> 00:55:02.670
to just task force.
Correct.
00:55:02.670 --> 00:55:05.040
So a task force can plan something,
00:55:05.040 --> 00:55:06.990
a pilot project implements something.
00:55:06.990 --> 00:55:09.390
And what Commissioner MCAdams has suggested
00:55:09.390 --> 00:55:10.710
is that we do the pilot project,
00:55:10.710 --> 00:55:13.920
but the task force is kind of the overseer.
00:55:13.920 --> 00:55:18.180
This thing is gonna, I'm happy with that being in parallel.
00:55:18.180 --> 00:55:19.710
Correct.
There are some major issues
00:55:19.710 --> 00:55:21.540
that have to be addressed, that are being addressed
00:55:21.540 --> 00:55:23.850
all across this country and that have to be addressed
00:55:23.850 --> 00:55:28.850
in this docket to ensure that costs are fair and equitable,
00:55:28.860 --> 00:55:30.450
that timelines are met,
00:55:30.450 --> 00:55:35.450
that ERCOT issues are addressed for reliability.
00:55:36.720 --> 00:55:39.990
And I think the process that Commissioner McAdams
00:55:39.990 --> 00:55:43.500
has put forth will help us do that in an expedited fashion.
00:55:43.500 --> 00:55:47.130
And I'm very appreciative of his leadership.
00:55:47.130 --> 00:55:51.750
I think that, these are issues that will add megawatts,
00:55:51.750 --> 00:55:54.150
there's lots of evidence out there that shows
00:55:54.150 --> 00:55:57.870
that these types of aggregation,
00:55:57.870 --> 00:56:01.320
virtual power plants, generation on the distribution system
00:56:01.320 --> 00:56:03.930
will all storage on the distribution system,
00:56:03.930 --> 00:56:05.943
all add reliability benefits.
00:56:08.273 --> 00:56:12.180
So we're not to lag behind were to help lead this effort.
00:56:12.180 --> 00:56:14.010
And I think that we are doing that.
00:56:14.010 --> 00:56:16.696
Absolutely.
Yeah.
00:56:16.696 --> 00:56:18.300
We got a task force for the pilot project
00:56:18.300 --> 00:56:21.300
that can then be overseen by the task force.
00:56:21.300 --> 00:56:23.800
And that is exactly what we're not trying to do.
00:56:25.800 --> 00:56:27.480
The task force vision.
00:56:27.480 --> 00:56:29.790
And again, I don't wanna steal thunder from my memo.
00:56:29.790 --> 00:56:31.980
I like having things in writing.
00:56:31.980 --> 00:56:35.253
That again, we can all adopt it, adhere to.
00:56:35.253 --> 00:56:37.287
It's a fantastic memo.
Yeah, well--
00:56:37.287 --> 00:56:39.247
You mean the future one?
The future one.
00:56:39.247 --> 00:56:40.080
Oh, it's gonna be really good.
00:56:40.080 --> 00:56:40.913
It's perspective.
00:56:40.913 --> 00:56:41.853
Wait, it's great.
00:56:43.200 --> 00:56:45.840
But it would delineate a process for the task force
00:56:45.840 --> 00:56:49.290
and the overall accountability measures for the task force.
00:56:49.290 --> 00:56:52.410
This thing is to exist as long as the pilot does to advise
00:56:52.410 --> 00:56:54.900
us on what are the operational hiccups that are being
00:56:54.900 --> 00:56:57.930
experienced real time and how do we overcome those.
00:56:57.930 --> 00:57:02.070
And to make Woody's life painful, which is,
00:57:02.070 --> 00:57:04.020
seems to be the goal of this Commission.
00:57:04.020 --> 00:57:04.980
Let me say one other thing.
00:57:04.980 --> 00:57:08.700
And that is, this pilot concept was brought up
00:57:08.700 --> 00:57:10.440
by one company.
00:57:10.440 --> 00:57:12.510
This is not a one company pilot.
00:57:12.510 --> 00:57:15.150
This is, there are lots of technologies out there.
00:57:15.150 --> 00:57:16.440
There are lots of opportunities.
00:57:16.440 --> 00:57:18.000
There are lots of different systems.
00:57:18.000 --> 00:57:20.220
So we want this to be broad and diverse.
00:57:20.220 --> 00:57:21.990
We don't want this to be about one company
00:57:21.990 --> 00:57:24.720
and we wanna understand the benefits of these
00:57:24.720 --> 00:57:25.830
with different technologies.
00:57:25.830 --> 00:57:28.890
So I just wanna make sure that everybody who is interested
00:57:28.890 --> 00:57:31.710
wants to know that this is part of that effort.
00:57:31.710 --> 00:57:33.540
Right now, I have a running list of 32
00:57:33.540 --> 00:57:35.850
potential stakeholders to be considered for the task force.
00:57:35.850 --> 00:57:38.580
Those are entities, not individuals.
00:57:38.580 --> 00:57:41.010
So that's why we're trying to make this manageable
00:57:41.010 --> 00:57:43.200
because it is broad in scope.
00:57:43.200 --> 00:57:45.930
I'm sure Tiffany, we hear from anymore.
00:57:45.930 --> 00:57:47.040
She will indeed.
00:57:47.040 --> 00:57:49.860
Also as a call out to the public
00:57:49.860 --> 00:57:51.270
and the stakeholder community,
00:57:51.270 --> 00:57:56.270
we are in search of interested non optin entities who might
00:57:56.730 --> 00:57:59.550
consider availing themselves off the pilot project,
00:57:59.550 --> 00:58:02.730
municipal utilities and electric cooperatives.
00:58:02.730 --> 00:58:06.150
So we can better, so we have a as broad of a potential
00:58:06.150 --> 00:58:09.390
sample population and sample of systems,
00:58:09.390 --> 00:58:13.300
distribution systems who could exercise
00:58:14.760 --> 00:58:16.623
the capabilities of DERs.
00:58:18.180 --> 00:58:20.010
Now, Mr. Chairman, after that,
00:58:20.010 --> 00:58:24.750
I would like to dovetail into a broader conversation about
00:58:24.750 --> 00:58:29.063
distribution generation resources, which has become a--
00:58:29.063 --> 00:58:29.896
Before we dive into that.
Yes, sir.
00:58:29.896 --> 00:58:31.503
A couple closing thoughts.
00:58:33.270 --> 00:58:35.610
Of course, I know ERCOT wanna make sure everybody listening
00:58:35.610 --> 00:58:37.560
at home knows ERCOT will be involved in this.
00:58:37.560 --> 00:58:40.950
This is not a exclusively Commission initiative.
00:58:40.950 --> 00:58:42.240
Absolutely.
00:58:42.240 --> 00:58:47.240
And then lastly, the, as these scoping efforts,
00:58:48.330 --> 00:58:51.300
key questions, key metrics are identified
00:58:51.300 --> 00:58:53.130
and these issues are worked through,
00:58:53.130 --> 00:58:54.840
of course you will come back.
00:58:54.840 --> 00:58:57.090
You all collectively will come back and brief
00:58:57.090 --> 00:59:00.120
this Commission and the public on the scope,
00:59:00.120 --> 00:59:05.120
scale and specs if you will, of the pilot project
00:59:06.060 --> 00:59:07.680
before anything is plugged in.
00:59:07.680 --> 00:59:08.886
Yes sir.
00:59:08.886 --> 00:59:09.750
Just wanna make sure the books,
00:59:09.750 --> 00:59:10.710
I know that's your intention.
00:59:10.710 --> 00:59:12.150
That's why we're gonna put things in writing.
00:59:12.150 --> 00:59:13.050
You will see them.
00:59:13.050 --> 00:59:15.810
Make sure the folks at home know that this is gonna be,
00:59:15.810 --> 00:59:17.970
this process will include visibility,
00:59:17.970 --> 00:59:19.860
what that will look like.
Yes, sir.
00:59:19.860 --> 00:59:21.359
All right. Thank you.
00:59:21.359 --> 00:59:23.276
On the issue of DGRs,
00:59:24.330 --> 00:59:28.320
a parallel proceeding at the Commission or project
00:59:28.320 --> 00:59:31.620
at the suggestion and urging of Commissioner Gloftfelty
00:59:31.620 --> 00:59:36.060
is pursuing better and more uniformed interconnection
00:59:36.060 --> 00:59:40.350
of DGRs at distribution level.
00:59:40.350 --> 00:59:43.803
Key word distribution, distributed generation resources.
00:59:44.850 --> 00:59:49.850
And look, operational issues are becoming apparent
00:59:50.790 --> 00:59:54.180
or operational implications are becoming apparent
00:59:54.180 --> 00:59:57.030
that we will need to have a clear view on
00:59:57.030 --> 00:59:58.620
in the coming months.
00:59:58.620 --> 01:00:02.640
And one of those, and we can bring stakeholders up
01:00:02.640 --> 01:00:05.730
to discuss this, but the reason I'm flagging it here
01:00:05.730 --> 01:00:07.440
is because I believe this Commission
01:00:07.440 --> 01:00:11.220
as a part of that project will need to make decisions
01:00:11.220 --> 01:00:15.600
and give guidance to both ERCOT and our TDSPs
01:00:15.600 --> 01:00:20.600
to help them actually allocate the bandwidth
01:00:20.880 --> 01:00:24.030
to solve some of these problems in the near future.
01:00:24.030 --> 01:00:27.030
Commissioner Gloftfelty has been a leader on this.
01:00:27.030 --> 01:00:29.970
I have become aware of it because it fits in,
01:00:29.970 --> 01:00:33.690
and it impacts the overall allocation of resources
01:00:33.690 --> 01:00:37.050
to be able to accommodate the DER pilot as well.
01:00:37.050 --> 01:00:41.913
So what in my view we must overcome is,
01:00:43.020 --> 01:00:45.510
is we've gotta do our part to make hard decisions,
01:00:45.510 --> 01:00:49.740
to give guidance to stakeholders and the grid administrator
01:00:49.740 --> 01:00:53.040
so that it doesn't become a choice of killing off
01:00:53.040 --> 01:00:54.300
one project over the other,
01:00:54.300 --> 01:00:57.240
because we simply don't have the manpower
01:00:57.240 --> 01:01:00.783
or the policies adopted to accommodate both.
01:01:01.650 --> 01:01:06.150
And as such Mr. Chairman, if you'll humor me,
01:01:06.150 --> 01:01:09.750
I'd like to invite up a couple of folks to talk through
01:01:09.750 --> 01:01:13.323
some of those situations that have become apparent.
01:01:15.240 --> 01:01:17.133
It'll be short.
Invited testimony.
01:01:18.840 --> 01:01:19.673
Not much.
01:01:21.000 --> 01:01:23.190
Good. Go ahead.
I second.
01:01:23.190 --> 01:01:25.593
Would Liz Jones and Woody Rickerson approach.
01:01:35.460 --> 01:01:38.040
Okay, thank you both for coming up.
01:01:38.040 --> 01:01:39.690
I'm gonna set the table now.
01:01:39.690 --> 01:01:42.540
One of the issues that has become apparent
01:01:42.540 --> 01:01:46.770
is interconnection of DGRs at distribution
01:01:46.770 --> 01:01:51.480
that are participating in ancillary services,
01:01:51.480 --> 01:01:56.480
have a special qualification at ERCOT
01:01:56.940 --> 01:01:59.160
and especially for our TDSPs
01:01:59.160 --> 01:02:02.220
in terms of their emergency planning processes.
01:02:02.220 --> 01:02:06.580
Those DGRs by definition, under ERCOT, NERC
01:02:06.580 --> 01:02:10.380
and Liz will explain all the restraints in a moment.
01:02:10.380 --> 01:02:13.740
Cannot be rolled as a part of an emergency plan.
01:02:13.740 --> 01:02:15.153
They cannot be rotated.
01:02:16.470 --> 01:02:21.470
That's a key condition that causes operational issues.
01:02:24.480 --> 01:02:27.030
If a feeder cannot be rolled everything beyond
01:02:27.030 --> 01:02:29.670
that feeder cannot be rolled.
01:02:29.670 --> 01:02:32.820
And thus, if everything's critical,
01:02:32.820 --> 01:02:35.580
then nothing's critical to your point, Mr. Chairman.
01:02:35.580 --> 01:02:40.580
And this presents one of the key policy decisions we're,
01:02:41.280 --> 01:02:44.190
I believe we're gonna need to make sooner rather than later,
01:02:44.190 --> 01:02:48.930
so that they can actually address issues that will come up
01:02:48.930 --> 01:02:52.740
as part of the pilot on DERs and the interconnection of vast
01:02:52.740 --> 01:02:55.710
amounts of batteries that could occur at distribution
01:02:55.710 --> 01:02:58.710
that want to avail themselves of ancillary services,
01:02:58.710 --> 01:03:00.480
which is good for the system,
01:03:00.480 --> 01:03:02.190
because we're gonna need more of that sooner
01:03:02.190 --> 01:03:05.610
rather than later, but we've gotta work out some details.
01:03:05.610 --> 01:03:08.190
Liz was kind enough to bring this to our attention.
01:03:08.190 --> 01:03:11.520
We had a small stakeholder work group on the issue
01:03:11.520 --> 01:03:15.180
and Commissioner Gloftfelty and I are both briefed up,
01:03:15.180 --> 01:03:18.060
but Liz, could you explain the issue for us.
01:03:18.060 --> 01:03:18.893
Liz, if you on, just a moment,
01:03:18.893 --> 01:03:20.493
we have a audio problem.
01:03:29.400 --> 01:03:31.410
Liz, go forward.
Sorry.
01:03:31.410 --> 01:03:32.883
Liz Jones for Oncor.
01:03:34.680 --> 01:03:39.680
The way the distribution resource construct was originally
01:03:40.920 --> 01:03:45.600
undertaken at ERCOT provides that a distribution resource
01:03:45.600 --> 01:03:48.753
providing ancillary services must be exempt from load check.
01:03:49.920 --> 01:03:54.180
That in turn has a consequence for at least my company.
01:03:54.180 --> 01:03:59.180
And I think others that a bay in the substation
01:04:00.000 --> 01:04:03.000
has to be dedicated to that particular resource
01:04:03.000 --> 01:04:04.860
so that they can be on a separate feeder
01:04:04.860 --> 01:04:09.860
so that we can meaningfully move forward with the emergency
01:04:10.110 --> 01:04:13.230
operations plans that we hope not to have to use.
01:04:13.230 --> 01:04:17.100
But nonetheless must maintain according to Commission,
01:04:17.100 --> 01:04:20.520
ERCOT and NERC responsibilities.
01:04:20.520 --> 01:04:23.220
So we can keep access to the reserves in that battery
01:04:23.220 --> 01:04:27.090
without preventing more granular load chip.
01:04:27.090 --> 01:04:32.090
So the conversation that we began having, and that I'm,
01:04:32.730 --> 01:04:34.800
I think ERCOT will engage in.
01:04:34.800 --> 01:04:38.160
I'm not sure they have an answer yet is,
01:04:38.160 --> 01:04:43.160
at the transmission level, QSE providing ancillary services
01:04:43.380 --> 01:04:47.940
do not do so on a specific resource basis.
01:04:47.940 --> 01:04:51.750
In other words, they commit to providing X megawatts
01:04:51.750 --> 01:04:53.400
of responsive reserve,
01:04:53.400 --> 01:04:56.760
but they don't say it's gonna come from this plant
01:04:56.760 --> 01:04:58.200
or that plant.
01:04:58.200 --> 01:05:02.310
The question becomes then whether a similar policy might
01:05:02.310 --> 01:05:06.030
and should be adopted for distribution resources,
01:05:06.030 --> 01:05:11.030
such that it would not be a TDSP obligation to isolate
01:05:12.120 --> 01:05:17.120
and ensure ongoing, constant, more near constant access
01:05:18.600 --> 01:05:23.600
subject to substation poll, whatever else, interruptions.
01:05:25.050 --> 01:05:29.220
And that rather the QSE who holds those resources
01:05:29.220 --> 01:05:33.840
in this case, the immediate object is the DERs source.
01:05:33.840 --> 01:05:37.470
The distribution interconnected batteries is instead
01:05:37.470 --> 01:05:41.190
responsible for ensuring access to that appropriate amount
01:05:41.190 --> 01:05:45.660
of reserves in however they choose to do so.
01:05:45.660 --> 01:05:49.320
So rather than having to determine if there's some kind of
01:05:49.320 --> 01:05:52.290
discount factor that needs to be applied because
01:05:52.290 --> 01:05:56.430
distribution resources may or may not be readily available,
01:05:56.430 --> 01:06:00.990
we instead pull back from the dedicated feeder rule,
01:06:00.990 --> 01:06:03.480
which is in place at ERCOT right now.
01:06:03.480 --> 01:06:06.420
And turn instead to the more general principle that it is up
01:06:06.420 --> 01:06:10.770
to resources to ensure that they have availability
01:06:10.770 --> 01:06:12.993
of quantities and kinds that they have bid.
01:06:14.400 --> 01:06:17.580
And presumably consistent with penalties,
01:06:17.580 --> 01:06:20.970
if they fail to provide the resources they've obligated.
01:06:20.970 --> 01:06:23.850
Yes, and the Commission has demonstrated
01:06:23.850 --> 01:06:26.650
a history of enforcement accountability in that respect.
01:06:28.230 --> 01:06:31.053
So please Commissioner--
Go on.
01:06:32.190 --> 01:06:36.360
The reason to flag this is because everything
01:06:36.360 --> 01:06:39.360
that we're doing right now is imposing human resource
01:06:39.360 --> 01:06:44.360
and manpower constraints on them as in Liz's company Oncor
01:06:44.700 --> 01:06:47.700
and all of the transmission distribution service providers
01:06:47.700 --> 01:06:51.213
in terms of policy making and planning.
01:06:52.440 --> 01:06:55.440
It also does that on ERCOT staff.
01:06:55.440 --> 01:07:00.420
So the reason Woody Rickerson has been called up is because
01:07:00.420 --> 01:07:04.650
it's to frame how insurmountable a challenge is this,
01:07:04.650 --> 01:07:07.050
so that the Commission can weigh all of that.
01:07:07.050 --> 01:07:10.140
And then if we can help by making basic decisions
01:07:10.140 --> 01:07:12.660
and giving guidance, then we should do that.
01:07:12.660 --> 01:07:15.840
Do so in the future, after we digest all the facts.
01:07:15.840 --> 01:07:19.320
But Woody tell me, given the way Liz has shaped this,
01:07:19.320 --> 01:07:21.660
this is a distribution problem that eventually trickles
01:07:21.660 --> 01:07:23.760
its way up to transmission system management,
01:07:23.760 --> 01:07:25.710
which is your world.
That's right.
01:07:25.710 --> 01:07:27.960
So Woody Rickerson with ERCOT.
01:07:27.960 --> 01:07:30.060
Just a little bit of history.
01:07:30.060 --> 01:07:33.330
We have been working on this for three or four years.
01:07:33.330 --> 01:07:35.580
And the big disconnect is that ERCOT
01:07:35.580 --> 01:07:37.110
looks at the transmission system.
01:07:37.110 --> 01:07:40.170
We model the transmission system and we don't model
01:07:40.170 --> 01:07:44.673
or actively take data from distribution companies.
01:07:46.710 --> 01:07:49.290
The distribution load is represented
01:07:49.290 --> 01:07:53.880
in the ERCOT control model, but it's not explicitly modeled.
01:07:53.880 --> 01:07:55.890
So this has been going on for several years.
01:07:55.890 --> 01:07:59.250
We had a, at one point we had a DGR moratorium.
01:07:59.250 --> 01:08:01.800
We said you can't connect the ERCOT system.
01:08:01.800 --> 01:08:04.890
We worked through those issues with the TSPs,
01:08:04.890 --> 01:08:06.930
with the DGR developers.
01:08:06.930 --> 01:08:10.200
And beginning this year we implemented
01:08:10.200 --> 01:08:11.850
a DGR interconnection process.
01:08:11.850 --> 01:08:16.850
So we are now able to reliably interconnect DGRs
01:08:16.860 --> 01:08:20.880
to the system and get their power up to the transmission
01:08:20.880 --> 01:08:25.276
system and our SCD system and EMS and MMS
01:08:25.276 --> 01:08:27.750
and everything else can works with that scenario.
01:08:27.750 --> 01:08:30.120
So we've got that, we can do that now.
01:08:30.120 --> 01:08:33.090
And that's a, I think that's a major foundation
01:08:33.090 --> 01:08:35.340
to build all these other things on.
01:08:35.340 --> 01:08:39.300
So right now you're saying DGR batteries
01:08:39.300 --> 01:08:43.970
can be connected at and deploy discharge into a Oncor
01:08:43.970 --> 01:08:45.600
at what level?
01:08:45.600 --> 01:08:48.090
At both the distribution, at the distribution level,
01:08:48.090 --> 01:08:50.730
they can put their power into the wholesale market
01:08:50.730 --> 01:08:52.260
and be dispatched.
01:08:52.260 --> 01:08:54.697
At the distribution and transmission level.
01:08:54.697 --> 01:08:55.530
That's right, both.
01:08:55.530 --> 01:08:57.360
That's a business decision for that battery company.
01:08:57.360 --> 01:08:58.350
That's right.
01:08:58.350 --> 01:09:00.660
But they currently right now can connect
01:09:00.660 --> 01:09:02.490
at both transmission and distribution level.
01:09:02.490 --> 01:09:03.323
That's right.
01:09:03.323 --> 01:09:06.270
We have an active, not only that, but we put together
01:09:06.270 --> 01:09:09.960
a small generator interconnection process.
01:09:09.960 --> 01:09:13.770
So the process as small generator goes through
01:09:13.770 --> 01:09:18.660
to interconnect is not the same as 100 megawatt generator.
01:09:18.660 --> 01:09:20.460
So it's an expedited process.
01:09:20.460 --> 01:09:22.620
We've done a lot of work to build a foundation,
01:09:22.620 --> 01:09:23.720
to make all this work.
01:09:24.900 --> 01:09:26.760
What Liz brought up is is there though
01:09:26.760 --> 01:09:28.620
this dedicated feeder idea.
01:09:28.620 --> 01:09:30.690
But I do think there are ways that we can work around that
01:09:30.690 --> 01:09:32.190
and we can investigate that.
01:09:32.190 --> 01:09:35.700
And so we're on board with working through the remaining
01:09:35.700 --> 01:09:37.680
problems, but I think we've already kicked a bunch
01:09:37.680 --> 01:09:39.150
of those problems already.
01:09:39.150 --> 01:09:40.770
Yeah, and another question.
01:09:40.770 --> 01:09:44.560
If they battery wants to connect at the distribution level
01:09:45.420 --> 01:09:49.290
and participate slowly, entirely in the realtime market
01:09:49.290 --> 01:09:53.160
or the day ahead market, not in ancillary services,
01:09:53.160 --> 01:09:57.870
does it still need a dedicated bay dedicated feeder?
01:09:57.870 --> 01:09:59.940
Not under the current ERCOT rules.
01:09:59.940 --> 01:10:01.263
Okay, so right now.
01:10:02.160 --> 01:10:05.010
So the distinction is we have resources
01:10:05.010 --> 01:10:09.450
that are further out on the, a distribution feeder populated
01:10:09.450 --> 01:10:13.050
by all kinds of customers and resources.
01:10:13.050 --> 01:10:16.980
And the question is they would very much like to access
01:10:16.980 --> 01:10:18.330
ancillary service markets.
01:10:18.330 --> 01:10:20.220
So that's one population.
01:10:20.220 --> 01:10:25.220
The other population is, some DESR developers
01:10:28.350 --> 01:10:31.530
who are finding that the cost implications
01:10:31.530 --> 01:10:34.500
of interconnecting at a dedicated feeder
01:10:34.500 --> 01:10:39.500
are burdensome and they can articulate that better than I.
01:10:40.770 --> 01:10:44.190
And there's been a lot of push and pull over how
01:10:44.190 --> 01:10:47.820
those burdensome costs, if you will, should be allocated.
01:10:47.820 --> 01:10:51.810
And it's a tough nut to crack.
01:10:51.810 --> 01:10:56.040
And so it may be that ERCOT concludes that the dedicated
01:10:56.040 --> 01:10:59.820
feeder is the only reasonable alternative.
01:10:59.820 --> 01:11:03.780
And if so, that will lead the next discussion,
01:11:03.780 --> 01:11:06.900
which is appropriate cost allocation,
01:11:06.900 --> 01:11:11.463
but rather than continuing to struggle with that,
01:11:12.360 --> 01:11:17.360
we're asking for ERCOT and batteries and wires companies
01:11:17.670 --> 01:11:22.650
to consider whether there is an alternative that reduces
01:11:22.650 --> 01:11:24.810
the time and the money to interconnect
01:11:24.810 --> 01:11:26.290
in that very particular way.
01:11:26.290 --> 01:11:28.980
Okay, but I want to be clear before people start
01:11:28.980 --> 01:11:30.450
saying that not you all,
01:11:30.450 --> 01:11:35.170
but the broader stakeholder universe
01:11:36.150 --> 01:11:39.960
or media, general public starts hearing that batteries
01:11:39.960 --> 01:11:42.060
can't connect to ERCOT.
01:11:42.060 --> 01:11:42.893
That's not true.
01:11:42.893 --> 01:11:44.310
They can connect at the transmission level.
01:11:44.310 --> 01:11:47.430
They can connect at the distribution level right now today.
01:11:47.430 --> 01:11:50.580
Yes.
This is only about batteries
01:11:50.580 --> 01:11:55.170
that want special access to a special bucket of revenue
01:11:55.170 --> 01:11:57.570
in the ancillary services,
01:11:57.570 --> 01:11:59.370
but otherwise they could participate
01:11:59.370 --> 01:12:00.780
in the normal energy market.
01:12:00.780 --> 01:12:03.165
They can participate in the forward market without
01:12:03.165 --> 01:12:06.300
any changes being made made right now today, correct?
01:12:06.300 --> 01:12:07.890
Yes.
Mr. Chairman,
01:12:07.890 --> 01:12:11.610
I would say that that small little market ancillary service
01:12:11.610 --> 01:12:15.480
market and the products within that are what are becoming
01:12:15.480 --> 01:12:18.090
the most important parts for grid reliability in the future,
01:12:18.090 --> 01:12:20.670
as we have ramping needs obviously frequency,
01:12:20.670 --> 01:12:24.060
and we have regulation up and down.
01:12:24.060 --> 01:12:27.450
We need those for the reliability of the system
01:12:27.450 --> 01:12:29.910
and getting more in there, lowers the cost of this
01:12:29.910 --> 01:12:33.870
and provides us additional backups for when we have other
01:12:33.870 --> 01:12:35.670
providers that are not in the system.
01:12:35.670 --> 01:12:37.650
That's fine, happy to have all of the above,
01:12:37.650 --> 01:12:40.920
but I want to be clear that there is nothing in place today,
01:12:40.920 --> 01:12:44.070
preventing batteries from accessing the ERCOT market
01:12:44.070 --> 01:12:45.570
at both the transmission or distribution over.
01:12:45.570 --> 01:12:48.120
Well, so let me just say the one thing that might be
01:12:48.120 --> 01:12:53.120
preventing them is a undefined process that has TDSPs
01:12:54.000 --> 01:12:56.160
doing things at different times,
01:12:56.160 --> 01:13:01.050
putting different costs on them and not allowing them
01:13:01.050 --> 01:13:03.270
any certainty in the process.
01:13:03.270 --> 01:13:04.710
This is what we did.
01:13:04.710 --> 01:13:06.720
Only if they wanna access ancillary services.
01:13:06.720 --> 01:13:09.030
Correct, but this is what we did
01:13:09.030 --> 01:13:11.970
in the generation interconnection process 20 years ago,
01:13:11.970 --> 01:13:14.670
was we created the entire framework,
01:13:14.670 --> 01:13:17.100
irrespective of what they wanted to participate in.
01:13:17.100 --> 01:13:19.200
We created the framework to make sure that
01:13:19.200 --> 01:13:20.490
the interconnection happened,
01:13:20.490 --> 01:13:22.410
that the interconnection costs were understood
01:13:22.410 --> 01:13:24.930
and that the timelines were understood by all parties
01:13:24.930 --> 01:13:26.640
and those that wanna finance them.
01:13:26.640 --> 01:13:29.763
So if we can get that box put together,
01:13:30.900 --> 01:13:33.600
I think that that helps us.
01:13:33.600 --> 01:13:35.580
We are gonna have to address these issues sooner
01:13:35.580 --> 01:13:36.413
rather than later.
01:13:36.413 --> 01:13:39.600
This is an effort that is warranted
01:13:39.600 --> 01:13:41.520
and these questions need to be answered.
01:13:41.520 --> 01:13:44.430
I just wanna make sure the public is clear.
01:13:44.430 --> 01:13:45.263
Got it.
01:13:45.263 --> 01:13:48.150
That there is other than access to the ancillary services
01:13:48.150 --> 01:13:50.940
market, which is at 6,500 megawatts
01:13:50.940 --> 01:13:53.673
out of our 75,000 megawatt market,
01:13:55.950 --> 01:13:58.800
this is only about access to that special
01:13:58.800 --> 01:14:00.050
little bucket of revenue.
01:14:01.170 --> 01:14:04.410
And I don't, I'm trying to avoid the misrepresentation
01:14:04.410 --> 01:14:06.660
that ERCOT won't allow batteries to connect.
01:14:06.660 --> 01:14:08.010
That's all I'm trying to avoid.
01:14:08.010 --> 01:14:09.210
These questions need to be answered,
01:14:09.210 --> 01:14:11.410
the more information we can have the better.
01:14:12.450 --> 01:14:15.990
And we certainly want all of the above resources across
01:14:15.990 --> 01:14:18.090
the spectrum real time, day ahead,
01:14:18.090 --> 01:14:19.590
every version of ancillary,
01:14:19.590 --> 01:14:21.150
just trying to avoid misrepresentation.
01:14:21.150 --> 01:14:24.610
I'm not in any way trying to indicate that this is not
01:14:26.251 --> 01:14:28.980
a prudent and necessary process.
01:14:28.980 --> 01:14:30.560
Thank you.
01:14:30.560 --> 01:14:31.770
And cap that all off.
01:14:31.770 --> 01:14:36.420
I see battery developers out in the room and fear not
01:14:36.420 --> 01:14:40.950
the reason this is flagged is because there needs
01:14:40.950 --> 01:14:45.950
focused Commission level work groups on this topic
01:14:46.740 --> 01:14:48.720
to help work through the operational issues
01:14:48.720 --> 01:14:50.910
that we just flagged.
01:14:50.910 --> 01:14:53.700
And that's why I wanted to suggest this and raise it
01:14:53.700 --> 01:14:56.040
in the context of the DERs 'cause that's exactly
01:14:56.040 --> 01:14:57.723
what we're proposing on the DERs.
01:14:58.710 --> 01:15:03.030
However, another focus of this Commission is the bandwidth
01:15:03.030 --> 01:15:06.780
of our key regulated utilities and the grid administrator.
01:15:06.780 --> 01:15:09.630
So that's why I wanted kind of a head nod
01:15:09.630 --> 01:15:14.630
from Mr. Rickerson and also Ms. Jones is whether we can work
01:15:17.760 --> 01:15:22.110
through this first operational obstacle in a timely way
01:15:22.110 --> 01:15:26.700
that helps ease the administrative burden
01:15:26.700 --> 01:15:30.480
on solving this problem in the near future.
01:15:30.480 --> 01:15:33.900
Do we believe that is accomplishable given everything else
01:15:33.900 --> 01:15:36.360
you are tasked with doing right now?
01:15:36.360 --> 01:15:39.630
Yes, especially if you give us more resources.
01:15:39.630 --> 01:15:40.463
All right.
01:15:41.460 --> 01:15:42.720
Can I say something?
01:15:42.720 --> 01:15:45.450
Obviously, the staff is something that we are all challenged
01:15:45.450 --> 01:15:50.450
with, both in the PUC, within ERCOT, within the TDSPs.
01:15:53.610 --> 01:15:58.530
We all have our costs covered, all of us.
01:15:58.530 --> 01:16:00.270
The customer pays our costs,
01:16:00.270 --> 01:16:02.430
but when we have merchant generators who are out there
01:16:02.430 --> 01:16:04.020
or merchant batteries that are trying to connect
01:16:04.020 --> 01:16:05.910
to the system, it is not their money.
01:16:05.910 --> 01:16:07.560
It is investor money.
01:16:07.560 --> 01:16:11.070
And they, I believe we owe it to them to make these
01:16:11.070 --> 01:16:14.400
processes timely, understood,
01:16:14.400 --> 01:16:17.280
because they are spending somebody else's money
01:16:17.280 --> 01:16:19.050
that is not recoverable,
01:16:19.050 --> 01:16:21.240
unless they make it into the market.
01:16:21.240 --> 01:16:22.650
That's risk capital.
01:16:22.650 --> 01:16:25.080
That's very different than rate return capital.
01:16:25.080 --> 01:16:28.770
And we owe them the benefit of the doubt
01:16:28.770 --> 01:16:30.300
to make these things happen.
01:16:30.300 --> 01:16:33.990
And I know that some of the transmission owners
01:16:33.990 --> 01:16:35.880
they've been wanting to do this,
01:16:35.880 --> 01:16:39.330
they've been wanting to interconnect storage
01:16:39.330 --> 01:16:41.340
at the distribution level for many years,
01:16:41.340 --> 01:16:42.900
that they would own.
01:16:42.900 --> 01:16:45.960
And I guarantee the issues would be resolved very quickly
01:16:45.960 --> 01:16:47.220
if they owned them.
01:16:47.220 --> 01:16:50.220
And I encourage them to continue to push
01:16:50.220 --> 01:16:53.220
and use that expedited effort that they would,
01:16:53.220 --> 01:16:54.770
if it was their own generation.
01:16:56.100 --> 01:16:58.230
Good for our TDSPs.
01:16:58.230 --> 01:17:01.263
Commissioner Gloftfelty, just to clarify.
01:17:04.080 --> 01:17:08.910
Our ability to run our company and to successfully seek
01:17:08.910 --> 01:17:13.910
great recovery of our costs is directly tied to our ability
01:17:14.100 --> 01:17:18.780
to meet the customer needs and resources are customers too.
01:17:18.780 --> 01:17:20.283
And we firmly believe that.
01:17:21.210 --> 01:17:24.930
They are as important a customer as the people in houses
01:17:24.930 --> 01:17:28.470
or the people in a refinery.
01:17:28.470 --> 01:17:31.533
And we view them that way.
Good.
01:17:33.840 --> 01:17:35.160
So I think the point Mr. Chairman
01:17:35.160 --> 01:17:36.930
is between our two offices,
01:17:36.930 --> 01:17:39.480
we're gonna establish that work group and work through
01:17:39.480 --> 01:17:43.020
the process concurrent to the straw man development
01:17:43.020 --> 01:17:46.680
that is ongoing within the stakeholder community right now,
01:17:46.680 --> 01:17:49.230
and their engagement with our own PUC staff,
01:17:49.230 --> 01:17:54.230
and then bring this back as decisions need to be made
01:17:54.420 --> 01:17:57.930
on our part to ensure timely implementation.
01:17:57.930 --> 01:17:59.928
Well, makes sense.
01:17:59.928 --> 01:18:01.830
And as you say,
01:18:01.830 --> 01:18:03.270
we don't know the answers to any of these things.
01:18:03.270 --> 01:18:04.650
The point is to get the process moving,
01:18:04.650 --> 01:18:08.430
get the informed stakeholders involved to make sure
01:18:08.430 --> 01:18:12.780
we can start driving towards a well-informed decision point.
01:18:12.780 --> 01:18:14.430
Yes.
Correct.
01:18:14.430 --> 01:18:15.263
Excellent.
01:18:16.440 --> 01:18:17.690
All right, thank you all.
01:18:20.511 --> 01:18:21.761
You're curious.
01:18:23.228 --> 01:18:24.300
Certainly for, thank you.
01:18:24.300 --> 01:18:26.160
Leadership on that Commissioner MCAdams
01:18:26.160 --> 01:18:27.480
and Commissioner Gloftfelty.
01:18:27.480 --> 01:18:29.610
Thank y'all for leading the charge.
01:18:29.610 --> 01:18:33.680
We don't have anything on item 26 through 32,
01:18:40.380 --> 01:18:42.300
which brings us to item number 33.
01:18:42.300 --> 01:18:46.266
Commissioner Cobos has an update for us on transmission.
01:18:46.266 --> 01:18:47.190
All right.
01:18:47.190 --> 01:18:49.110
Thank you, Mr. Chairman.
01:18:49.110 --> 01:18:50.700
I thought it would be a great opportunity to provide
01:18:50.700 --> 01:18:53.250
an update on the Rio Grande Valley transmission facilities
01:18:53.250 --> 01:18:56.520
that the Commission ordered this past October.
01:18:56.520 --> 01:18:59.130
Given all the in recent interests by the legislature
01:18:59.130 --> 01:19:01.320
on transmission infrastructure development,
01:19:01.320 --> 01:19:03.960
to relieve congestion, state, and recent activity
01:19:03.960 --> 01:19:05.550
associated with the Rio Grande Valley
01:19:05.550 --> 01:19:09.210
transmission facilities that were ordered by the Commission.
01:19:09.210 --> 01:19:10.380
Just for background purposes.
01:19:10.380 --> 01:19:13.620
Again, last October, the Commission took action.
01:19:13.620 --> 01:19:16.440
Utilized, never report been used statutory authority
01:19:16.440 --> 01:19:20.400
to order construction of transmission lines of facilities
01:19:20.400 --> 01:19:24.000
in the Rio Grande Valley to ensure safe and reliable service
01:19:24.000 --> 01:19:24.833
in the area.
01:19:25.950 --> 01:19:28.860
The Rio Grande Valley facilities that we have ordered
01:19:28.860 --> 01:19:33.860
addressed seven of 16 existing GTCs in the state
01:19:33.990 --> 01:19:37.470
and will push back the reliability need in the area
01:19:37.470 --> 01:19:42.470
to 2033 and provide much needed resiliency
01:19:42.900 --> 01:19:46.230
in this hurricane tropical storm prone area.
01:19:46.230 --> 01:19:51.230
So with respect to recent activity, as you may recall,
01:19:51.570 --> 01:19:54.870
we ordered a second line to be added to a double circuit
01:19:54.870 --> 01:19:59.163
capable line that runs from San Miguel to the Palmetto.
01:20:00.090 --> 01:20:03.000
And then also ordered what we called at the time
01:20:03.000 --> 01:20:05.610
close-the-loop transmission facilities in the deep,
01:20:05.610 --> 01:20:06.873
lower Rio Grande Valley.
01:20:08.521 --> 01:20:10.560
These close-the-loop project is now called
01:20:10.560 --> 01:20:12.870
Palmetto King Fisher.
01:20:12.870 --> 01:20:16.500
And so pursuant to our order,
01:20:16.500 --> 01:20:19.510
a joint application was filed by Sherry Land in AP, Texas
01:20:20.760 --> 01:20:24.630
yesterday on Wednesday, June 29th, 2022
01:20:24.630 --> 01:20:26.190
for these facilities.
01:20:26.190 --> 01:20:28.500
And it's my understanding based on conversations I've had
01:20:28.500 --> 01:20:30.990
with the company that they expect to have these facilities
01:20:30.990 --> 01:20:34.020
energized by April 2026.
01:20:34.020 --> 01:20:36.810
It is a very congested area with a lot of folks
01:20:36.810 --> 01:20:37.643
living down there.
01:20:37.643 --> 01:20:40.710
And so those facilities are expected to be in line.
01:20:40.710 --> 01:20:45.710
Then, as far as the second circuit that runs from Sal Miguel
01:20:45.780 --> 01:20:48.600
to Palmetto there, as you may recall,
01:20:48.600 --> 01:20:52.530
there is no CCN amendment necessary for this line
01:20:52.530 --> 01:20:55.320
and the energization based on the progress reports
01:20:55.320 --> 01:20:57.270
that I received from the companies that are responsible
01:20:57.270 --> 01:20:59.820
for building this line would occur,
01:20:59.820 --> 01:21:02.373
are expected to occur by June, 2024.
01:21:03.330 --> 01:21:06.180
So progress is being made,
01:21:06.180 --> 01:21:11.010
and I just wanted to appraise you of those transmission
01:21:11.010 --> 01:21:13.950
facilities provided with an update on those transmission
01:21:13.950 --> 01:21:16.980
facilities that we ordered this past Fall.
01:21:16.980 --> 01:21:18.750
With respect to the long term project,
01:21:18.750 --> 01:21:21.960
the new 345 KB transmission project that I believe
01:21:21.960 --> 01:21:23.810
will be built by AEP taxes and stock.
01:21:26.280 --> 01:21:29.760
AEP is starting to develop their CCN process.
01:21:29.760 --> 01:21:34.680
I mean, their CCN application and their expectation
01:21:34.680 --> 01:21:37.200
is that they would have the line energized three years
01:21:37.200 --> 01:21:40.260
after the Commission approves the CCN application.
01:21:40.260 --> 01:21:44.070
So expected goal is end of 2026.
01:21:44.070 --> 01:21:47.550
So by 2026, we'll have all these facilities in place
01:21:47.550 --> 01:21:50.310
that we ordered and deem critical for reliability
01:21:50.310 --> 01:21:52.530
in the Rio Grande Valley area.
01:21:52.530 --> 01:21:55.350
And as you've said in the past resiliency.
01:21:55.350 --> 01:21:56.850
Yes, sir.
The line going down
01:21:56.850 --> 01:22:01.260
the center of the valley and the Western line are critical.
01:22:01.260 --> 01:22:03.960
In case we have a weather event in the Gulf of Mexico,
01:22:04.830 --> 01:22:07.200
and we need additional power going into,
01:22:07.200 --> 01:22:08.640
or coming out of the valley.
01:22:08.640 --> 01:22:11.640
These three lines are really important for resiliency
01:22:11.640 --> 01:22:13.560
in the valley.
Yeah.
01:22:13.560 --> 01:22:15.273
Very important point, thank you.
01:22:16.620 --> 01:22:17.730
Thank you for that update.
01:22:17.730 --> 01:22:22.730
This is a hugely important project for both reliability
01:22:23.670 --> 01:22:26.160
and resiliency, not only for the Rio Grande Valley,
01:22:26.160 --> 01:22:28.683
but for the broader ERCOT system.
01:22:29.520 --> 01:22:33.750
And as we've all seen throughout this process,
01:22:33.750 --> 01:22:36.120
this would not have happened without your leadership.
01:22:36.120 --> 01:22:38.580
Thank you for taking the lead on this.
01:22:38.580 --> 01:22:41.820
And I can't overemphasize how important
01:22:41.820 --> 01:22:43.560
this transmission project is.
01:22:43.560 --> 01:22:45.543
Thank you.
Thank you.
01:22:47.280 --> 01:22:49.443
Don't have anything on 34,
01:22:51.300 --> 01:22:53.580
which brings us to item 35, Mr. Jenay.
01:22:55.765 --> 01:22:56.833
Item 35 is project 53353.
01:22:58.290 --> 01:23:01.980
It's a request for our proposals to provide live internet
01:23:01.980 --> 01:23:04.650
video coverage of public hearing to meetings
01:23:04.650 --> 01:23:06.810
at this Commission.
01:23:06.810 --> 01:23:08.880
Commission staff filed a memo and proposed order
01:23:08.880 --> 01:23:12.180
that would delegate authority to the executive director.
01:23:12.180 --> 01:23:13.013
Thank you, sir.
01:23:13.013 --> 01:23:15.630
Thoughts, comments, or motion to approve the proposed order.
01:23:15.630 --> 01:23:17.550
So moved.
Second.
01:23:17.550 --> 01:23:18.383
All in favor, say aye.
01:23:18.383 --> 01:23:19.216
Aye.
Aye.
01:23:20.490 --> 01:23:22.110
None opposed, motion passes.
01:23:22.110 --> 01:23:26.400
We don't have anything on 36 through 40.
01:23:26.400 --> 01:23:29.040
So having convened in a duly notice open meeting,
01:23:29.040 --> 01:23:33.150
the Commission will now at 10:53 AM on June 30th, 2022,
01:23:33.150 --> 01:23:35.520
hold a closed session pursuant to Chapter 551 Texas
01:23:35.520 --> 01:23:39.765
government code section 5510.071, 5510.074
01:23:39.765 --> 01:23:44.103
and 5510.076, we'll be back in a bit.
01:23:47.550 --> 01:23:48.990
And those would you all who won't be sticking around,
01:23:48.990 --> 01:23:50.240
have a Happy 4th of July.
01:23:54.900 --> 01:23:57.060
Concerning, well, hold on a second.
01:23:57.060 --> 01:23:59.340
We are now back in open session,
01:23:59.340 --> 01:24:02.490
closed session is here about concluded at 11:10 AM
01:24:02.490 --> 01:24:04.920
on June 30th, 2022.
01:24:04.920 --> 01:24:08.043
And our public meeting is now resumed.
01:24:09.840 --> 01:24:11.310
Considering the discussion and closed session.
01:24:11.310 --> 01:24:13.170
I'll entertain a motion to request representation
01:24:13.170 --> 01:24:15.270
from the attorney general to join TCQ
01:24:15.270 --> 01:24:20.270
as a petitioner in Texas V Stone Hinge Utility company,
01:24:20.280 --> 01:24:25.280
course number D1GN22-2804 in Travis County, Texas.
01:24:29.760 --> 01:24:30.593
Is there a motion?
01:24:30.593 --> 01:24:32.280
So moves.
Second.
01:24:32.280 --> 01:24:33.113
All in favor, say aye.
01:24:33.113 --> 01:24:34.230
Aye.
Aye.
01:24:34.230 --> 01:24:36.510
None opposed, motion passes.
01:24:36.510 --> 01:24:37.343
Thank you all.
01:24:37.343 --> 01:24:39.480
Having no further business before this Commission,
01:24:39.480 --> 01:24:41.340
this meeting of the Public Utility Commission of Texas
01:24:41.340 --> 01:24:45.423
hereby adjourned, (tapping gavel) Happy 4th.