WEBVTT

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Good morning. This meeting of the Public Utility Commission

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of Texas will come to order to consider matters that

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have been duly posted with the Secretary of State for

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October 2020 23 for the record. My name is Kathleen

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Jackson and I'm joined by Will McAdams, Lori Cobos

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and Jimmy Glotfelty. The primary focus of this work

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session is for the commission to receive updates on

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winter preparedness in the ERCOT region. We are tentatively

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planning to take a lunch break between 12 and one depending

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on the length of the discussion. This morning discussion

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on the ERCOT RFP for contracts for capacity is scheduled

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to begin no earlier than two o'clock PM. Additionally

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unless y'all want to discuss any other posted items

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will not be taking up items three through 16.

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So let's begin with item number one. General comments

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for topics not specifically posted on this agenda.

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Speakers will be limited to three minutes. Each commenters

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should not approach the table unless they've been invited

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Sheila, do we have anyone from the public signed up

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to speak? Good morning commissioners. No one has signed

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up for item number one and I will also note that no

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one has signed up for any of the items in the open

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meeting. Ok. Well, this completes item number one.

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Uh, next up is item number two, project number 55633

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This is the commission's project for today's work session

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Uh, Shean, you just mentioned that no one has, uh,

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from the public has signed up to speak on item number

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two. Correct? Ok. Well, then, um, for those here with

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us at the commission and for everyone viewing online

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all presentations that have been filed will be in project

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number 55633. Uh The Public Utility Commission market

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analysis staff are here to facilitate the work session

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They've worked really hard and uh we're ex excited

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for the day's um work that is ahead. Um They will be

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calling up our invited speakers. Uh Commissioner staff

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has set aside time and we'll be pausing periodically

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so that we can ask our questions. So, uh Hara and Mariah

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would you please come up and state your name? You are

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very good, good morning, everybody. So I'm just gonna

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describe what my role will be. I have here with me

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Mariah Ban from market analysis. She's in charge of

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slides. And uh what we'll do is we have four big topics

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and under each one, we have multiple panels and I will

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call on the panel and uh describe the subtopic but

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but they will be discussed. Please state your name

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and organization before you speak. And after you present

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we will leave time for the commissioners ask any questions

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they need. And uh after that, we will invite the next

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panel. Not all of the panel members have slides. So

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some of them will be very verbal. I will try to note

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that if I can.

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Is that good? Ok, very good. So, uh I guess we're gonna

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kick things off with um section one of the staff in

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the preparation, overview, preparation, overview. And

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the first panel is Urt Brandon Manley.

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All right, good morning commissioners. Good morning

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guests, madam chair. My name is Brandon Manley. I work

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at ERCOT as weatherization senior weatherization program

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analyst and I will be speaking with everybody today

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about our weatherization and inspection program.

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Next slide. Bye bye, bye, bye.

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Yeah.

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All right. So while our weatherization program is relatively

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new, ERCOT has been conducting inspections since 2011

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These inspections and site visits did not require any

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formal reporting or allow enforcement actions but were

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proactive steps. ERCOT took to share best practices

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and lessons learned in regarding hardening the grid

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against any weather related events. All these side

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visits.

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Excuse me. No,

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as we, as we all know, winter storm Uri kicked off

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a couple of years back here in 2021 and devastated

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most of Texas with freezing temperatures for approximately

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four days or more. These conditions cause generators

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of all types to experience outages and delivery issues

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Many Texans called for increased accountability from

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service providers, utilities, system operators and

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state government. This would lead to Senate bill three

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being passed by our state legislature and then signed

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into law by Governor Abbott in 2021.

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In that same year, the commission established the first

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phase of winter weather preparedness standards in this

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sense of rule 25 55 for generation and transmission

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facilities to summarize this rule, states that generation

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entities and transmission service providers must complete

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weather emergency preparedness measures for each resource

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or facility under their control. The rule also assigned

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several responsibilities to ERCOT including the assignment

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to execute on site inspections. Now, at a, we have

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a team of inspectors and each of these inspectors is

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very well qualified. They've been working on a lot

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of this equipment, they've been had their hands on

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this transmission equipment as well as the generation

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equipment for the majority of their career. So they're

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very well qualified to perform these inspections. Violations

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of this rule will be subject to commission enforcement

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investigation and potential penalties.

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No.

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So in September of last year, a phase two of weather

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emergency preparedness standards went into effect which

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would include summer weatherization would, would include

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summer weatherization standards with us completing

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our first phase this past summer between June and September

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All right. In addition, phase two introduced a provision

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for a cure period to allow correction of identified

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deficiencies in required weather emergency preparation

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measures. The intent is to initiate a process for resolving

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any potential equipment risks that have been identified

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as well and to take action required to mitigate against

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these weather emergencies. The idea here is to provide

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the the market participants an opportunity and just

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to clarify, I use the term market participants. I'm

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referring to the generation entities and the transmission

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service providers. Um This is an opportunity for those

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market participants to resolve any items that are identified

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or any compliance deficiencies that are identified

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in the course of this inspection for this upcoming

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winter inspection season. Some additional provisions

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have also been made that will take effect December

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1st. These will include a weather zone specific temperature

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that the market participants will have to assure that

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their equipment can withstand as well as a requirement

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to create a list of cold weather critical components

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which will be required to be reviewed annually and

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updated as necessary.

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So, regarding the day to day logistics of the weatherization

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and inspection program, we have performed we winter

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weatherization inspections under the 25 55 rule for

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two winter seasons. So 21 22 as well as 22 and 23

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and then we just completed our first summer weatherization

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inspection season. Uh This past summer

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inspections will be executed. They're inspected by

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both our internal ERCOT inspector team, as well as

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our contract inspector teams which are qualified and

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trained by ERCOT personnel before we go ahead and send

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them out in the field.

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The rule also requires that all generation resources

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be inspected every three years and 10% of all of the

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transmission service providers are inspected every

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year, which is essentially our guide for determining

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how many inspections and what inspections we're going

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to be performing each season.

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All market participants at the beginning at the beginning

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of the season will be required to submit declarations

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of weather preparedness twice a year that are signed

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by the generation entity and transmission service providers

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Quote, highest ranking representative official or officer

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with binding authority attesting to the completion

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of all applicable activities. End quote.

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Here we go. So high level, what does the inspection

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process actually look like? So typically the way ERCOT

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does it is once, once around the time May and November

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rolls around, we issue a market notice. This market

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notice goes out to all the transmission service providers

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and the generation entities informing them that they

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have requirements that have to be met by the first

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of that respective season. So by June 1st, by December

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1st, each of those market participants is required

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to submit a declaration of weather preparedness as

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well as an attestation that they've met all the requirements

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of the rule.

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Once all of those declarations are submitted, then

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a goes ahead and looks at looks at all of those declarations

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and works on putting together a compliance report that's

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gonna be provided to the commission by December 20th

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or June 20th of each year. This is essentially saying

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these are all the market participants that have adhered

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to the rule and submitted their, their declarations

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and accompanying documents on time. As well as those

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who are targeting those who are late.

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Once that process is done, we move into issuing a notice

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of inspection. These notices of inspection are the

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official form of communication with the market participants

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informing them that they will have an inspector that's

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going to arrive on site on a particular date. Now,

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we're required to give them 72 hours of notice ahead

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of time, but we will do our best to give them as

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much advance notice as reasonably possible.

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Once those, once those notices of inspection or NOIS

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go out and the market participant, again, the generation

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entity or the transmission service provider acknowledges

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that they've received it and that they will have somebody

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provided on site for our inspectors to meet. Then our

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inspector will go out to the site and they will perform

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the inspection. This is very collaborative. This is

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an opportunity to work with both the market participant

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in making sure they're aware of what those requirements

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are. Mind. You, they should have read the rule by this

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time but really educating them and letting them know

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that, hey, these are what the requirements are and

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these are some of the expectations and then working

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with them to identify where the potential deficiencies

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or discrepancies or essentially any risks that might

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be provided. And really the overarching point is to

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make sure they're adhering to the rule. Once that inspection

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is complete, then ERCOT will provide the market participants

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with a inspection report. There's gonna be a cover

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letter that identifies which resources or substation

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or facility was inspected as well as an outline of

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all the items that were identified during that inspection

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Now, if there are compliance deficiencies that are

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identified, then what's gonna happen is depending on

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if it's a something that can be resolved very quickly

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in which we can work with them on site to get that

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item resolved or if it's something that's gonna take

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longer, then we'll issue them a cure period. All right

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this cure period is a, this care period is determined

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by ERCOT after considering different factors and conferring

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with the market participant to determine what timeline

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would be appropriate in resolving these types of issues

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Now, once those, once that cure period has been assigned

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then they're required to give biweekly updates saying

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what the status is on getting that item, that deficiency

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resolved.

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The vast majority, the vast majority of compliance

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deficiencies have been resolved within their cure period

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within their given cure periods, which is a good signal

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because what that means is that the market participants

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are being very collaborative and responsive to the

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rule and to the, the guidance that's given from our

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inspectors. They're resolving these issues when they're

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identified. For example, all cure periods for this

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past summer have been remedied and, and closed. So

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for context, about 3% of our inspections this past

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summer were identified as having cure periods and all

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those were resolved and closed out

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today. Ot So there's a, we have a chart up here. So

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today ERCOT has been successful in meeting our target

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number of inspections. So prior to kicking off our

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2021 winter inspection, we had approximately 1250 resources

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and approximately 5500 T SPS. Now, the rule again requires

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us to inspect all of these resources within a three

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year time period and then 10% of those T SPS. Hence

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our 1800 goal to date, we're at 1648 inspections and

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on track to surpass our initial goal of this 23 24

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season.

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So some key takeaways uh pu weatherization, emergency

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preparedness rule is having a beneficial effect on

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system reliability. Market. Participants have been

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really responsive to the new role and the on site inspectors

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they're inquiring into options to improve performance

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and preparedness as well as resolving cure periods

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in a timely fashion

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that said continued collaboration and mark participant

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diligence in weatherization, preparation and maintenance

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will be critical to ensuring reliability improvements

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And then finally, weatherization inspection levels

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are ahead of pace in meeting the requirements while

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inspections are critical to ensuring reliability to

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the grid ERCOT S weatherization and inspection team

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will also continue to proactively identify opportunities

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to work with these markets to increase the reliability

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of the system. And with that, I will go ahead and conclude

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with the final announcement. Next week, we have an

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upcoming winter weatherization workshop that's gonna

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be on the 26th. That will be another opportunity for

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any market participants, any guests, anybody that's

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participating in this call to ask additional questions

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and receive any additional um answers that they might

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have to this upcoming winter inspection season. So

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with that, I appreciate your time and thank you for

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having me today. Any questions from the commissioners

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if, if I may Brandon, thank you for coming today as

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as a percentage, how much of our system and really

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I'm concerned about the generation facilities right

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now with my question targeted on that has been inspected

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over the last two years since we've implemented the

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weatherization reforms. So you said we have 1200 total

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facilities, generation facilities of some type of variant

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in system in 2021 about 1250 generation facilities

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1250 in 2021 that's not counting any new generation

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that's been commissioned since then. So in terms of

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the universe of overall generation in system, how much

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of that has been viewed by your inspectors over since

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the reforms were put into place.

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It's a good question, Commissioner. Give me, let me

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see if I have those numbers for you

00:15:44.450 --> 00:15:45.859
and if not we can get back to that at the end

00:15:45.869 --> 00:15:48.979
of the program to save time as well. And, and this

00:15:48.989 --> 00:15:52.058
is collaborative madam chair. I think this is a collaborative

00:15:52.070 --> 00:15:53.979
setting. So

00:15:55.918 --> 00:15:58.690
looks like we've got some help coming for you. I don't

00:15:58.700 --> 00:16:00.349
have an answer either at the top of my head. But I

00:16:00.399 --> 00:16:02.690
think if there are, if there are questions you have

00:16:02.700 --> 00:16:05.038
that we don't have answers for, we can get you something

00:16:05.048 --> 00:16:06.759
filed or provided to your offices as well.

00:16:09.119 --> 00:16:13.038
I have a follow up question. So um the first round

00:16:13.048 --> 00:16:16.308
of phase one weather weatherization preparation requirements

00:16:16.320 --> 00:16:19.500
were focused on at least through the inspection process

00:16:19.509 --> 00:16:22.849
on um generation plants that had had issues during

00:16:22.859 --> 00:16:28.649
winter storm. And so that was for, I guess winter 21

00:16:28.658 --> 00:16:33.580
22 and, and then we still had phase one through 22

00:16:33.590 --> 00:16:36.408
23 and now we'll have phase two. So what, what's the

00:16:36.418 --> 00:16:40.469
process of the first focus was on the units that had

00:16:40.479 --> 00:16:44.710
issues during winter storm Uri, how do you then select

00:16:44.719 --> 00:16:49.178
units after that? So commissioner, if, if I'm understanding

00:16:49.190 --> 00:16:52.869
the question, how are units selected, generation units

00:16:52.879 --> 00:16:56.469
or T SPS either or generation focused generation? So

00:16:56.479 --> 00:16:59.000
we're required to inspect all of them over the course

00:16:59.009 --> 00:17:01.519
of the three years. So one of the processes that's

00:17:01.710 --> 00:17:04.880
currently ongoing is once a a new generation unit comes

00:17:04.968 --> 00:17:07.868
online, we're intending to inspect those new ones as

00:17:07.878 --> 00:17:10.077
soon as they come online. Now, we already know that

00:17:10.087 --> 00:17:13.259
the ones that were online in 2021 forward, we have

00:17:13.269 --> 00:17:15.417
that three year. It's, it's already ticking. So our

00:17:15.428 --> 00:17:17.868
goal is to make sure we capture those three inside

00:17:17.878 --> 00:17:20.317
of or those generation entities inside of the three

00:17:20.327 --> 00:17:23.828
years. Now, new generation that comes online. Another

00:17:23.838 --> 00:17:26.039
goal is to make sure as soon as they come online, we're

00:17:26.049 --> 00:17:28.598
doing an inspection on site to make sure that all of

00:17:28.608 --> 00:17:32.199
the items that they were required to meet during that

00:17:32.209 --> 00:17:34.400
phase three commissioning have been met, but they'll

00:17:34.410 --> 00:17:36.959
still have a rating requirement and an attestation

00:17:36.969 --> 00:17:39.098
requirement in terms of the rating capabilities of

00:17:39.108 --> 00:17:42.009
their facility. Correct? I mean, it's a newly installed

00:17:42.019 --> 00:17:45.368
facility theoretically, it's going to have the manufacturer's

00:17:45.380 --> 00:17:48.189
warranty and rating in terms of the temperatures that

00:17:48.199 --> 00:17:50.858
they can withstand in compliance with our rule. Correct

00:17:51.799 --> 00:17:53.598
I'm not sure. I understand your question. Brand new

00:17:53.608 --> 00:17:56.118
facilities should work when cold temperatures happen

00:17:58.098 --> 00:18:00.779
Yes, they have to meet the requirements prior to getting

00:18:00.789 --> 00:18:03.348
through commissioning three or stage three commissioning

00:18:04.150 --> 00:18:06.439
Well, in part, because of the work that was done with

00:18:06.449 --> 00:18:08.818
the windshield factor, which kind of set those standards

00:18:08.828 --> 00:18:13.439
very clearly in terms of what was needed to be put

00:18:13.449 --> 00:18:17.799
in place for that design as well as ongoing facilities

00:18:19.098 --> 00:18:21.390
I, I can't, I can't speak to that one. I'm sorry.

00:18:23.009 --> 00:18:24.039
No, that's good. Um

00:18:25.670 --> 00:18:28.789
Brennan, what in terms of your team, what percentage

00:18:28.799 --> 00:18:32.529
of inspectors are contractors or still in-house now

00:18:32.539 --> 00:18:34.650
Like where are we at? In terms of the evolution of

00:18:34.660 --> 00:18:38.328
the, the folks who are going out in the field and inspecting

00:18:38.338 --> 00:18:41.380
to the Standard Commission. I don't have the exact

00:18:41.390 --> 00:18:42.880
numbers. No, you get that.

00:18:45.368 --> 00:18:47.699
Ok. And just a point of clarification. Did you say

00:18:47.709 --> 00:18:50.989
that generation units have been being inspected since

00:18:51.000 --> 00:18:51.699
2011?

00:18:53.618 --> 00:18:56.118
Yes. So they've, we didn't have any official,

00:18:57.759 --> 00:18:59.848
we didn't have any official of enforcement authority

00:18:59.858 --> 00:19:02.699
to do it, but we've had on site inspections and visits

00:19:02.709 --> 00:19:06.059
since 2011 really sharing best practices and lessons

00:19:06.068 --> 00:19:10.719
learned from uh prior prior weather events and in preparation

00:19:10.729 --> 00:19:13.219
for any upcoming events. So those were those like voluntary

00:19:13.229 --> 00:19:18.818
weatherization measures at the time? I don't understand

00:19:18.828 --> 00:19:20.789
the question. Well, we didn't mandate weatherization

00:19:20.799 --> 00:19:23.789
requirements until 2021. So prior to then, were they

00:19:23.799 --> 00:19:28.910
voluntary? Yes. Ok. Thank you. Final question from

00:19:28.920 --> 00:19:33.868
me. Um So say you run on to a facility that's, that's

00:19:33.880 --> 00:19:37.019
pretty banged up over the years, an older facility

00:19:37.029 --> 00:19:40.910
that needs a lot of weatherization mitigation to meet

00:19:40.920 --> 00:19:44.338
the standard going into the next season. Does that

00:19:44.348 --> 00:19:48.459
facility get priority in terms of the MDR PO to take

00:19:48.469 --> 00:19:52.180
maintenance outages and cure the defects? Because I

00:19:52.189 --> 00:19:55.868
know those two policies somewhat are moving concurrently

00:19:55.880 --> 00:19:57.920
where you, you find deficiencies and then they've got

00:19:57.930 --> 00:20:00.559
to take some type of maintenance outage to comply.

00:20:00.809 --> 00:20:02.059
Is that synced up

00:20:04.108 --> 00:20:06.750
commissioner? The best way I can answer that is, is

00:20:06.920 --> 00:20:09.449
when we have an inspector that's on site. And if there's

00:20:09.459 --> 00:20:13.088
a cure period item identified, then we work with them

00:20:13.098 --> 00:20:15.529
to get it resolved. And again, those cure periods are

00:20:15.568 --> 00:20:17.789
any type of deficiencies of the rule and any potential

00:20:17.799 --> 00:20:21.130
risks that might be apparent at the time of that inspection

00:20:21.140 --> 00:20:23.459
Well, if they don't get it resolved, then they'll be

00:20:23.469 --> 00:20:25.868
reported and you know, that case will be escalated

00:20:26.160 --> 00:20:29.509
But as far as a follow up, we, I, I don't have

00:20:29.519 --> 00:20:30.809
an answer for you on that. Ok.

00:20:36.618 --> 00:20:40.219
Yes, I found a friend. So I think for the ramp up

00:20:40.229 --> 00:20:45.868
of the units, it was 302 in 2021 2022 22 3 was

00:20:45.880 --> 00:20:49.739
603. And this year is 905 generation units inspection

00:20:49.759 --> 00:20:52.799
So we will have, by this year, we will have accomplished

00:20:52.809 --> 00:20:56.049
the full fleet will have been inspected since winter

00:20:56.108 --> 00:20:59.779
storm. It's been a lot more units as we ramp up as

00:20:59.809 --> 00:21:02.578
we ramp up the program. I think that's the goal. I

00:21:03.500 --> 00:21:05.519
think having those figures would be helpful. Right

00:21:05.529 --> 00:21:08.029
Absolutely. Makes me feel better.

00:21:13.410 --> 00:21:16.469
Any other questions? No. Thank you so much, Brandon

00:21:16.479 --> 00:21:19.910
Thank you. The next panel on the same topic is transmission

00:21:19.920 --> 00:21:23.459
and distribution utilities. And we will invite Encor

00:21:23.500 --> 00:21:27.608
CenterPoint AP, Texas, TN MP and LC A.

00:21:30.199 --> 00:21:31.199
You want to do?

00:21:33.828 --> 00:21:34.410
I think I do.

00:21:38.368 --> 00:21:38.699
Ok.

00:21:41.930 --> 00:21:42.059
I know

00:21:43.858 --> 00:21:43.930
this is,

00:21:50.689 --> 00:21:51.219
ah, ok.

00:21:53.009 --> 00:21:54.318
Ok. So.

00:21:58.390 --> 00:21:58.420
Mhm.

00:22:00.009 --> 00:22:00.150
So

00:22:05.818 --> 00:22:08.358
who wants to go first? So we can pull up the slides

00:22:10.959 --> 00:22:11.140
Oncor.

00:22:19.049 --> 00:22:20.750
Mhm. What the

00:22:30.449 --> 00:22:30.630
Yes.

00:22:35.959 --> 00:22:39.900
Ok. Yeah, please. Sorry, thank you. Um, my name is

00:22:39.910 --> 00:22:42.500
Alex MAOA. I'm the senior director for Transmission

00:22:42.509 --> 00:22:47.670
of Racism and Construction at Alcor. Um, not knowing

00:22:47.680 --> 00:22:51.750
what I needed to present exactly. Uh I kind of wanted

00:22:51.759 --> 00:22:55.068
to start off with. We will be ready for the winter

00:22:55.289 --> 00:22:58.430
Uh, we've done, we've gone through the rules, we've

00:22:58.439 --> 00:23:01.588
identified what we need to do. We've updated our procedures

00:23:01.750 --> 00:23:04.939
we are 50% towards executing our winter preparedness

00:23:05.180 --> 00:23:07.709
as far as looking at all our stations and doing what

00:23:07.719 --> 00:23:10.239
needs to be done to prepare for the winter. Kind of

00:23:10.250 --> 00:23:14.509
that first box is what we're doing. Currently, the

00:23:14.519 --> 00:23:16.699
other boxes is touching on our cold weather critical

00:23:16.709 --> 00:23:19.939
components and the items that they inspect and, and

00:23:19.949 --> 00:23:24.118
kind of to my statement that we will make sure by December

00:23:24.130 --> 00:23:27.838
1st that we're ready for the winter. The bottom part

00:23:27.848 --> 00:23:29.949
of this slide is kind of the things that we've done

00:23:30.098 --> 00:23:33.660
based on. We've had, this will be our third winter

00:23:33.670 --> 00:23:36.250
inspection and we've learned some lessons. We work

00:23:36.259 --> 00:23:39.039
together with the inspectors and we've identified areas

00:23:39.049 --> 00:23:42.410
where we need to improve. And every winter we get some

00:23:42.420 --> 00:23:44.989
lessons learned and we implement those. I'd say probably

00:23:45.000 --> 00:23:47.229
the biggest one out of the five bullets at the bottom

00:23:47.239 --> 00:23:49.799
is making sure that with the supply chain constraints

00:23:49.809 --> 00:23:53.098
that we have enough inventory to make the repair. Once

00:23:53.108 --> 00:23:53.750
we identify

00:23:58.009 --> 00:23:59.309
next center point

00:24:01.068 --> 00:24:03.338
Good morning Patrick Reinhart, Vice President of Regulatory

00:24:03.348 --> 00:24:06.608
Relations and Policy for CenterPoint Energy similar

00:24:06.618 --> 00:24:09.539
to Oncor where we will be, we will be ready for this

00:24:09.549 --> 00:24:12.660
winter season. We're constantly in inspecting our substations

00:24:12.670 --> 00:24:15.430
and our facilities. We do the similar training that

00:24:15.439 --> 00:24:18.630
you see on the, on the slide up there. We coordinate

00:24:18.640 --> 00:24:21.809
our outages with Ira to make sure that there is sufficient

00:24:21.818 --> 00:24:26.209
uh transmission online. We drill our communication

00:24:26.219 --> 00:24:28.130
materials to make sure as we're communicating to the

00:24:28.140 --> 00:24:32.358
public as well. We periodically test our mobile generation

00:24:32.368 --> 00:24:35.229
fleet. I'll remind you all that we have 500 megawatts

00:24:35.239 --> 00:24:36.979
that the commission has approved. So those will be

00:24:36.989 --> 00:24:41.719
ready. Should the need arise? We have ongoing assessments

00:24:41.729 --> 00:24:45.140
of our air force f on our transmission systems to make

00:24:45.150 --> 00:24:48.500
sure there's any galloping conductors. If we have to

00:24:48.509 --> 00:24:51.390
move those facilities, we make adjustments based on

00:24:51.400 --> 00:24:53.650
the data and the weather information that we receive

00:24:53.660 --> 00:24:55.680
to make sure that we limit the number of galloping

00:24:55.689 --> 00:24:59.420
conductors that we have. We review our critical load

00:24:59.759 --> 00:25:03.380
list as you see there. And then obviously, we, as I

00:25:03.390 --> 00:25:07.150
mentioned at the outset, we're constantly engaging

00:25:07.160 --> 00:25:09.838
with our substation teams to make sure that they have

00:25:09.848 --> 00:25:12.380
the inventory and the facilities they need so that

00:25:12.390 --> 00:25:15.368
we will be prepared. So in short, we will be prepared

00:25:15.729 --> 00:25:19.410
for this winter season. Thank you A P Texas,

00:25:21.358 --> 00:25:24.019
Jessica Seuss, Director of Regulatory Services for

00:25:24.029 --> 00:25:28.439
a EP Texas, uh like my colleagues, we are going to

00:25:28.449 --> 00:25:34.250
be prepared for the winter season. We are checks and

00:25:34.259 --> 00:25:38.529
analysis are in full swing. We've reviewed the 25 55

00:25:38.539 --> 00:25:41.279
rules and are confident that we are going to be in

00:25:41.289 --> 00:25:45.088
compliance with them. We've currently completed over

00:25:45.098 --> 00:25:51.729
2900 heater checks and 1200 DG A samples. We did not

00:25:51.739 --> 00:25:55.559
experience any transmission station issues during winter

00:25:55.568 --> 00:25:59.568
storm Elliott last year. Uh So I think that is a good

00:25:59.578 --> 00:26:03.930
testament to our preparations. Uh We're building upon

00:26:03.939 --> 00:26:06.900
obviously everything that we've done in the past, but

00:26:06.920 --> 00:26:09.328
we're feeling very confident for the winter season

00:26:10.348 --> 00:26:13.828
Thank you, TN MP. Good morning Stacy Whitehurst for

00:26:13.838 --> 00:26:15.939
TN MP. Uh First of all, I just want to thank the

00:26:15.949 --> 00:26:18.078
commission for allowing us to come up here and talk

00:26:18.420 --> 00:26:22.368
Uh As ERCOT mentioned that the uh list of cro components

00:26:22.380 --> 00:26:25.750
in the review is scheduled by December 1st, what I

00:26:25.759 --> 00:26:30.568
have on here uh for your uh summer is a summary of

00:26:30.578 --> 00:26:34.118
TNPS winner annex. Uh I'm not planning on going through

00:26:34.130 --> 00:26:36.959
it all, but basically the list of critical components

00:26:36.969 --> 00:26:41.078
in the review is ongoing for TN MP with senior management

00:26:41.239 --> 00:26:44.259
engineering and substation management. Uh Additional

00:26:44.269 --> 00:26:46.618
training on the winner preparedness. Annex portion

00:26:46.630 --> 00:26:50.259
of TN MP, SEOP is being provided right now with the

00:26:50.430 --> 00:26:55.759
supervisors and uh evaporation folks, as you know,

00:26:55.769 --> 00:26:59.199
TNP does have four noncontiguous service territories

00:26:59.209 --> 00:27:03.809
So I just want to mention staffing right now. We currently

00:27:03.818 --> 00:27:07.318
are almost at a full staffing and the one thing we

00:27:07.328 --> 00:27:10.479
do, we do have a significant number of contractors

00:27:10.489 --> 00:27:13.680
on our system. And what we do is we evaluate, evaluate

00:27:13.689 --> 00:27:17.598
real-time conditions and preemptively move those contractors

00:27:17.608 --> 00:27:20.489
into different parts of our service territory. So we

00:27:20.500 --> 00:27:22.868
uh we can also move contractors from, from our Gulf

00:27:22.880 --> 00:27:26.049
coast area and employees from Gulf coast up to North

00:27:26.059 --> 00:27:29.039
Texas over West Texas, wherever we need to. And then

00:27:29.049 --> 00:27:32.969
additionally, ERCOT mentioned the substation inspections

00:27:33.209 --> 00:27:37.739
and so currently TFB has a little over 120 substations

00:27:37.750 --> 00:27:44.608
In 2023 almost 10% have been evaluated and we are ready

00:27:45.380 --> 00:27:46.809
Thank you, SCR A.

00:27:49.509 --> 00:27:51.880
Thank you. Good morning for the record. My name is

00:27:51.890 --> 00:27:54.539
Emily Jolly. I'm the senior Vice President of Regulatory

00:27:54.549 --> 00:27:57.739
Affairs for the Lower Colorado River Authority. I'm

00:27:57.750 --> 00:28:00.979
here today um on behalf of LC eight Transmission Services

00:28:00.989 --> 00:28:03.680
Corporation. And while we are also ready for the winter

00:28:03.689 --> 00:28:06.130
I was actually invited to speak on a different topic

00:28:06.289 --> 00:28:09.588
Um If the commissioners will uh entertain discussion

00:28:09.598 --> 00:28:13.328
of transmission outage coordinations at this time.

00:28:13.680 --> 00:28:13.949
Um

00:28:15.709 --> 00:28:19.229
Absolutely. Yeah, we are also prepared for the winter

00:28:21.930 --> 00:28:23.189
full stop.

00:28:26.910 --> 00:28:29.568
Ok. Commissioners, do you have any questions in this

00:28:29.578 --> 00:28:32.108
panel? No problem

00:28:34.068 --> 00:28:41.479
as it, as it relates to Wes for a encre and TN

00:28:41.489 --> 00:28:43.328
MP um

00:28:45.299 --> 00:28:50.279
in terms of concerns over congestion during peak periods

00:28:50.489 --> 00:28:55.880
So peak demand during winter, do you have policies

00:28:55.890 --> 00:29:01.098
or procedures in place to help us manage through that

00:29:01.108 --> 00:29:06.289
during a peak condition? Meaning and we'll get to CenterPoint

00:29:06.299 --> 00:29:08.660
in Houston Zone because that's another constrained

00:29:08.670 --> 00:29:14.219
area. But Mobile G to help ease some of those constraints

00:29:14.568 --> 00:29:16.420
at known points of congestion,

00:29:19.029 --> 00:29:22.150
West zone is, is a constrained area. Everyone knows

00:29:22.160 --> 00:29:27.009
that during winter with renewables possibly performing

00:29:27.390 --> 00:29:28.368
erratically,

00:29:30.239 --> 00:29:33.809
we need to know if there are systems in place on behalf

00:29:33.818 --> 00:29:34.769
of the TN mps

00:29:36.279 --> 00:29:39.318
under a weatherization plan or otherwise that could

00:29:39.328 --> 00:29:41.479
help manage through that. Are there any plans

00:29:43.680 --> 00:29:46.199
to help solve for this, Liz? I know you're approaching

00:29:46.209 --> 00:29:48.858
Stacy, you can have a crack at it or anybody.

00:29:50.650 --> 00:29:54.769
So commissioner, we endeavor to provide as much through

00:29:54.779 --> 00:29:58.150
flow as possible on the transmission system within

00:29:58.160 --> 00:30:04.799
the NRC standards. We do not deploy mobile gen unless

00:30:04.809 --> 00:30:10.078
or until there is an outage consistent with the amendment

00:30:10.088 --> 00:30:14.118
that was passed in the last legislative session. And

00:30:14.130 --> 00:30:19.809
under that amendment is that an ee a condition it could

00:30:19.818 --> 00:30:22.848
be but it need not be so it need not be. So

00:30:22.858 --> 00:30:26.269
for instance, if there is an ice storm and there is

00:30:26.608 --> 00:30:29.039
you know, critical infrastructure that has gone down

00:30:29.250 --> 00:30:32.549
we have the opportunity to deploy those and at least

00:30:32.559 --> 00:30:35.828
for Oncor, we have stationed them across our service

00:30:35.838 --> 00:30:39.229
area strategically. Yeah, it's a great question. So

00:30:39.239 --> 00:30:43.479
I think that it's sort of a dovetail, the t the transmission

00:30:43.489 --> 00:30:45.779
companies being ready from weatherization standpoint

00:30:45.789 --> 00:30:48.160
resiliency standpoint with some of the companies having

00:30:48.170 --> 00:30:51.078
mobile generation that can use be used under certain

00:30:51.088 --> 00:30:54.250
circumstances as you describe Liz for our role. Um

00:30:54.259 --> 00:30:56.380
Can you talk about some of the automation that's been

00:30:56.390 --> 00:31:00.640
done to help, um you know, alleviate, um you know,

00:31:00.650 --> 00:31:04.699
any kind of outage situation where we were made improvements

00:31:04.709 --> 00:31:09.250
since 21 just very high level in terms of automation

00:31:09.259 --> 00:31:11.098
under frequency relays, anything like that that's been

00:31:11.108 --> 00:31:19.529
done to um you know, reduce the time of outages. Uh

00:31:20.250 --> 00:31:23.368
staw for tap one thing that, you know, in our service

00:31:23.380 --> 00:31:26.269
territory in West Texas, we've had a significant amount

00:31:26.279 --> 00:31:28.400
of load, data center load, crypto load. And one of

00:31:28.410 --> 00:31:30.410
the things that we've done is with those interconnection

00:31:30.420 --> 00:31:33.439
agreements, we've asked them to uh register as a control

00:31:33.449 --> 00:31:36.598
load resource for RCO OT. And so that's hopefully giving

00:31:36.680 --> 00:31:39.539
IR C some flexibility out there on our system. But

00:31:39.549 --> 00:31:42.289
obviously, a lot of our interconnections are with uh

00:31:42.680 --> 00:31:44.618
encre and a EP out there

00:31:48.068 --> 00:31:50.939
and something I'll add, you know, our mobile generation

00:31:50.949 --> 00:31:53.939
is strategically placed across the system. And one

00:31:53.949 --> 00:31:57.568
of the things we've done in where they're, you know

00:31:57.578 --> 00:32:03.009
parked uh until we deploy them is those are at areas

00:32:03.019 --> 00:32:07.729
where we see a higher chance of need for them. And

00:32:07.739 --> 00:32:11.489
so that's going to be based on uh congestion or other

00:32:11.500 --> 00:32:14.469
factors, Patrick, I know you're chopping at the big

00:32:14.479 --> 00:32:17.459
So what do you see in Houston from a constrained perspective

00:32:17.469 --> 00:32:20.108
constrained perspective as well as well as utilization

00:32:20.118 --> 00:32:23.959
of mobile generation to solve for weather conditions

00:32:23.969 --> 00:32:27.989
that may be problematic So as you guys know, and everyone

00:32:28.000 --> 00:32:30.858
else knows, we import 60 to 70% of the power into the

00:32:30.868 --> 00:32:33.059
Houston region on an average basis. So transmission

00:32:33.068 --> 00:32:35.684
constraints are really to us. Again, that's part of

00:32:35.693 --> 00:32:38.814
why I mentioned in my earlier remarks that we're constantly

00:32:38.824 --> 00:32:40.983
working and reaching out with ERCOT to make sure that

00:32:40.993 --> 00:32:43.894
there's, there's not an issue importing that power

00:32:43.904 --> 00:32:46.483
that our customers need to make our communities function

00:32:46.493 --> 00:32:49.525
and run on a daily basis. So at this time, we don't

00:32:49.535 --> 00:32:52.660
foresee an issue from that perspective. While I have

00:32:52.670 --> 00:32:54.650
the microphone, I will point out similar to the other

00:32:54.660 --> 00:32:57.489
companies. We have our mobile generation units ready

00:32:57.500 --> 00:32:59.838
to go. They're strategically deployed throughout our

00:32:59.848 --> 00:33:03.500
service area. We have large units and small units that

00:33:03.509 --> 00:33:06.500
both can be mobilized in whatever weather condition

00:33:06.509 --> 00:33:08.884
that unfortunately hits our service area so that our

00:33:08.894 --> 00:33:11.854
customers don't experience the outages that they went

00:33:11.864 --> 00:33:14.733
through through. Winner Stormy with respect to your

00:33:14.743 --> 00:33:17.314
question, Commissioner. Any time there's an event,

00:33:17.324 --> 00:33:19.723
we always do an after action report internally. We've

00:33:19.733 --> 00:33:22.134
done some evaluations and I know our operators have

00:33:22.144 --> 00:33:25.535
deployed intelligent grid switching devices which are

00:33:27.078 --> 00:33:29.769
I'm a nonen engineer. So I apologize but they are devices

00:33:29.779 --> 00:33:32.318
that we put on our system to allow us to better manage

00:33:32.328 --> 00:33:35.039
the flow of electricity better. And so we're constantly

00:33:35.049 --> 00:33:37.309
deploying those kind of things to make sure we have

00:33:37.318 --> 00:33:40.529
the the or our customers have the power that they need

00:33:41.309 --> 00:33:45.019
And Commissioner Cobos. Are you speaking of outages

00:33:45.029 --> 00:33:48.559
that are, for instance, ice related or are you talking

00:33:48.568 --> 00:33:51.818
about outages that may result from a generation short

00:33:51.828 --> 00:33:55.838
supply? The second. Ok. With respect to the generation

00:33:55.848 --> 00:33:58.739
short supply. One of the steps that encre has undertaken

00:33:58.750 --> 00:34:04.239
is um fine tuning the portion of our feeders that are

00:34:04.250 --> 00:34:08.800
subject to under frequency load shed so that we can

00:34:08.809 --> 00:34:13.079
essentially rotate that feature as well as the manual

00:34:13.090 --> 00:34:16.250
load shed. So that in the unfortunate event, there

00:34:16.260 --> 00:34:22.059
is an hour longer days long, uh rolling outage rotation

00:34:22.349 --> 00:34:26.648
that we're sure that we have a broader population that

00:34:26.659 --> 00:34:31.889
is subject to briefer periods about it. Yes, thank

00:34:31.898 --> 00:34:34.110
you. And I know a lot of the companies have taken a

00:34:34.119 --> 00:34:38.409
lot of um steps to work on that, that goal that, that

00:34:38.418 --> 00:34:40.739
Liz just described and I just wanted to kind of touch

00:34:40.750 --> 00:34:43.378
on it because, you know, we we're trying to avoid those

00:34:43.389 --> 00:34:46.639
circumstances. But I think that the transmission and

00:34:46.648 --> 00:34:49.369
distribution companies have taken a lot of steps from

00:34:49.378 --> 00:34:51.550
what I've been briefed on over the last couple of years

00:34:51.559 --> 00:34:55.300
to minimize the impact of consumers. Should we have

00:34:55.309 --> 00:34:56.449
a rotating outage?

00:34:58.010 --> 00:35:02.300
I have one question and that is, have any of y'all's

00:35:02.309 --> 00:35:04.599
companies failed any inspections,

00:35:06.260 --> 00:35:08.659
any winter weatherization inspections that have been

00:35:08.668 --> 00:35:12.898
done by ERCOT. My question is not to put you on the

00:35:12.909 --> 00:35:16.360
spot. It's really to better understand if there are

00:35:16.369 --> 00:35:18.579
and there are companies. What is the type of element

00:35:18.590 --> 00:35:22.668
that that is the problematic challenge for CenterPoint

00:35:22.679 --> 00:35:26.228
Energy Commissioner, we have not failed. There have

00:35:26.239 --> 00:35:29.188
been what I would describe as minor deficiencies that

00:35:29.199 --> 00:35:32.300
we were able to cure very rapidly. Sometimes when the

00:35:32.309 --> 00:35:33.599
inspectors are on site,

00:35:35.989 --> 00:35:39.228
I believe A E Texas is in the same situation and that

00:35:39.239 --> 00:35:42.099
there have been no failures, but there have been some

00:35:42.110 --> 00:35:45.148
small deficiencies that we have been able to rectify

00:35:45.159 --> 00:35:51.079
to co's happiness. Similarly on call, wh they've inspected

00:35:51.090 --> 00:35:55.590
over 100 and 50 stations, I think in a few occasions

00:35:55.599 --> 00:35:59.059
they found findings not deficiencies necessarily that

00:35:59.070 --> 00:36:02.119
have been corrected on site. And then finally, Fortini

00:36:02.168 --> 00:36:05.239
P, that's similar for us that we have not had any major

00:36:05.250 --> 00:36:07.668
or any failures. It's just some minor remedies that

00:36:07.679 --> 00:36:11.280
have been able to uh quickly be addressed. And for

00:36:11.289 --> 00:36:15.010
LCATSE, um we've had several dozen inspections this

00:36:15.019 --> 00:36:18.708
summer season, we haven't had any issues and no material

00:36:18.719 --> 00:36:24.148
deficiencies. So, so is it fair to say that, um, you

00:36:24.159 --> 00:36:28.510
know, when, when we talk about the grid having problems

00:36:28.769 --> 00:36:31.389
that really, that's a generation side, the transmission

00:36:31.398 --> 00:36:34.699
system, you know, has historically not been a problem

00:36:34.708 --> 00:36:37.628
with winter weather events, although we can have those

00:36:37.639 --> 00:36:42.260
events with icing or with tornadoes or with hurricanes

00:36:42.269 --> 00:36:46.168
or, but cold weather isn't necessarily a challenge

00:36:46.179 --> 00:36:48.590
for the elements of the transmission system. Is that

00:36:48.599 --> 00:36:50.579
right? Distribution becomes effective though? I mean

00:36:51.668 --> 00:36:55.208
it could, it could for sure, but could I ask a follow

00:36:55.269 --> 00:36:58.349
up question to that. So part of the intent of putting

00:36:58.360 --> 00:37:02.438
in these weatherization rules was that, you know, owners

00:37:02.449 --> 00:37:05.610
whether transmission or generation would kind of take

00:37:05.619 --> 00:37:09.250
the initiative when they had an event. And maybe there

00:37:09.260 --> 00:37:14.039
was a part of the system that didn't perform as expected

00:37:14.369 --> 00:37:16.320
that they would take the initiative go in and do a

00:37:16.329 --> 00:37:20.449
root cause analysis and correct that. And so, you know

00:37:20.458 --> 00:37:24.500
which I see very much as a positive and so theoretically

00:37:24.510 --> 00:37:27.059
you're better prepared when the inspector comes out

00:37:27.070 --> 00:37:30.969
And so, I mean, does anybody have an example of maybe

00:37:30.978 --> 00:37:35.458
some aspect of that having occurred as a consequence

00:37:35.469 --> 00:37:39.530
of the rules being put in place and either, you know

00:37:39.539 --> 00:37:42.300
the transmission companies kind of doing those root

00:37:42.309 --> 00:37:44.800
cause analysis and determining something and kind of

00:37:44.809 --> 00:37:47.489
preventing it from becoming an issue. A bigger issue

00:37:49.728 --> 00:37:53.938
madam chair respectfully, I don't think so specific

00:37:53.949 --> 00:37:56.570
example because we're constantly monitoring our system

00:37:56.579 --> 00:38:00.500
to make sure it complies with, with what we need, what

00:38:00.510 --> 00:38:03.110
our customers expect, what they demand from us. So

00:38:03.119 --> 00:38:07.628
the rule is extremely important and we comply with

00:38:07.639 --> 00:38:10.929
the rule, but I can't cite a specific example where

00:38:10.958 --> 00:38:14.418
something occurred and as a result of the rule, we

00:38:14.429 --> 00:38:16.668
went back and did an analysis, but I I'll look into

00:38:16.679 --> 00:38:18.989
it and and can get back with your offices. Thank you

00:38:19.909 --> 00:38:22.728
for us. I'd say any time you get inspected, you're

00:38:22.760 --> 00:38:26.070
ready than ready, right? So, so I'd say there's a benefit

00:38:26.079 --> 00:38:29.438
to it. Uh But Oncor, historically, we do root cause

00:38:29.449 --> 00:38:34.050
analysis on our failures and mitigate or apply this

00:38:34.059 --> 00:38:37.269
all the lessons learned from it. I would say that's

00:38:37.280 --> 00:38:40.320
consistent with TNP. Uh Obviously, with our service

00:38:40.329 --> 00:38:42.820
territory, we have different events, uh cold weather

00:38:42.829 --> 00:38:46.610
events, whether in North Texas or West Texas or central

00:38:46.619 --> 00:38:49.989
Texas. And we're always going back and looking at what

00:38:50.000 --> 00:38:52.918
occurred and what uh lessons learned that we can give

00:38:52.929 --> 00:38:56.329
the other business units to uh help.

00:38:58.019 --> 00:39:02.478
And I again will echo everyone's sentiments. Uh I don't

00:39:02.489 --> 00:39:05.389
know of a specific example where there's been a root

00:39:05.398 --> 00:39:08.438
cause analysis where there wouldn't have been previously

00:39:08.648 --> 00:39:11.760
But I do think this rule has, you know, we're all sitting

00:39:11.769 --> 00:39:13.860
here and it's opened up a really good dialogue and

00:39:13.869 --> 00:39:18.449
even though we all have coordinate a lot and collaborated

00:39:18.458 --> 00:39:20.760
a lot in the past, I think it's opened that up even

00:39:20.769 --> 00:39:23.668
more uh for winter preparedness,

00:39:27.188 --> 00:39:30.208
I'd be remiss if I didn't say vegetation management

00:39:30.219 --> 00:39:30.648
Um

00:39:32.329 --> 00:39:35.389
obviously at the distribution level, it's, it's much

00:39:35.398 --> 00:39:37.800
more important, but this winter, gosh, go back and

00:39:37.809 --> 00:39:41.039
please look and make sure that your, your primary circuits

00:39:41.050 --> 00:39:46.228
are uh uh are cleaned and um you're up to date with

00:39:46.239 --> 00:39:48.260
your vegetation management cycles and plants.

00:39:50.599 --> 00:39:54.519
Any other questions for this panel? OK. Thank you so

00:39:54.530 --> 00:39:58.639
much. Next panel, the same topic, it will be generation

00:39:58.648 --> 00:40:04.000
entities and we invite Calpine NRG luminant, Texas

00:40:04.010 --> 00:40:07.719
electric cooperators and TPP A and there are no slides

00:40:07.728 --> 00:40:09.699
from this panel. It will be all bourbon.

00:40:12.188 --> 00:40:12.530
Ok.

00:40:27.489 --> 00:40:28.728
You wanna start with Calpine.

00:40:31.969 --> 00:40:33.898
Good morning. Thank you for the opportunity to come

00:40:33.909 --> 00:40:36.909
speak to you. My name is Mike Del Cassel. I'm the EP

00:40:36.918 --> 00:40:40.239
for Calpine for power operations. So I just want to

00:40:40.250 --> 00:40:43.050
start out by saying that Calpine uses a procedure or

00:40:43.059 --> 00:40:46.000
standard for preparing our plans for winter operation

00:40:46.010 --> 00:40:48.688
That's really, that includes not only ERCOT but our

00:40:48.699 --> 00:40:51.849
fleet nationwide. So when we look at winterization

00:40:51.860 --> 00:40:56.489
we base our standards on really an experiential type

00:40:57.228 --> 00:41:00.340
program where we go back and look every year, we can

00:41:00.349 --> 00:41:02.760
make improvements each year or problems that we've

00:41:02.769 --> 00:41:07.329
had during winter storms. So a lot of folks focus only

00:41:07.340 --> 00:41:13.119
on instrumentation and process programs to make sure

00:41:13.128 --> 00:41:14.909
because of the first things that freeze and the first

00:41:14.918 --> 00:41:17.458
things that give you problems when you're an operating

00:41:17.469 --> 00:41:21.889
fleet, we try to go beyond that. And based on our experiences

00:41:21.898 --> 00:41:23.820
that we've had, we've looked at a number of different

00:41:23.829 --> 00:41:27.860
things that have affected us over the years. So, and

00:41:27.869 --> 00:41:30.639
different storms will react different to how it affects

00:41:30.648 --> 00:41:33.179
a plant, a storm with different moisture content or

00:41:33.188 --> 00:41:35.688
wind in certain directions, could blow your cooling

00:41:35.699 --> 00:41:39.000
tower, plume your inlet filters of the combustion turbine

00:41:39.320 --> 00:41:41.539
or it could cause icing on your combustion turbine

00:41:41.889 --> 00:41:44.519
and cause it to get high differential pressure. So

00:41:45.250 --> 00:41:47.648
I just listed out a few things I wanted to go through

00:41:47.659 --> 00:41:50.969
today that make us different or make us that we think

00:41:50.978 --> 00:41:54.500
our program is sound and robust. So we not only look

00:41:54.510 --> 00:41:57.320
at instrumentation and processing critical instruments

00:41:57.610 --> 00:42:01.739
we look at our systems. So if you have areas of your

00:42:01.750 --> 00:42:03.739
air system where your air dryers aren't working, right

00:42:03.949 --> 00:42:07.030
they will freeze up over time. You will get moisture

00:42:07.039 --> 00:42:09.369
in your control, in your control valves, in your actuaries

00:42:09.378 --> 00:42:12.000
and your control valves and they will freeze up. So

00:42:12.010 --> 00:42:15.789
we do a pretty robust inspection of not only air dryers

00:42:15.800 --> 00:42:17.438
to make sure they're working. We go beyond that and

00:42:17.449 --> 00:42:19.648
make sure we don't have any saturate areas or dead

00:42:19.659 --> 00:42:23.099
areas in our air systems to make sure they go ammonia

00:42:23.110 --> 00:42:27.599
systems, ammonia systems will freeze both aqueous and

00:42:27.610 --> 00:42:30.539
anhydrous. Ammonia systems will freeze. If you can't

00:42:30.550 --> 00:42:32.619
get enough heat in there, you can't operate because

00:42:32.628 --> 00:42:35.628
you don't, you can't make the, the, the vapor out of

00:42:35.639 --> 00:42:39.938
the ammonia. People always forget extended coal periods

00:42:39.958 --> 00:42:42.780
will cause ice build up on your cooling tower fill

00:42:43.349 --> 00:42:47.469
You'll start getting your lactates long icicles hanging

00:42:47.478 --> 00:42:50.188
off your coin tower fill. If you don't manage your

00:42:50.199 --> 00:42:54.449
heat after extended periods of operation, you will

00:42:54.458 --> 00:42:56.958
start overloading your cooling tower. So you have to

00:42:56.969 --> 00:42:59.409
be very diligent of how you manage your heat across

00:42:59.418 --> 00:43:02.250
your cooling tower fill to make sure you prevent the

00:43:02.260 --> 00:43:05.250
build up of ice during the storm, sometimes even up

00:43:05.260 --> 00:43:07.869
to and including if it's cold enough, bypassing your

00:43:07.878 --> 00:43:09.878
cooling tower fill and just letting it, let it cool

00:43:09.889 --> 00:43:12.139
on its own and managing and raising the heat of the

00:43:12.148 --> 00:43:15.708
cooling tower through a limited number of cells, make

00:43:15.719 --> 00:43:18.659
up water screens. A lot of our sites pull water off

00:43:18.668 --> 00:43:21.398
of rivers off of bay areas off of different streams

00:43:21.840 --> 00:43:24.110
If you have a nice ice build up on top of the

00:43:24.119 --> 00:43:26.969
the, uh, where you're pulling your, your water off

00:43:26.978 --> 00:43:29.829
of, it will affect your ability to drive cooling into

00:43:29.840 --> 00:43:32.550
your, into your units. So we look at all these things

00:43:33.090 --> 00:43:36.619
uh gas regulation and expansion. Most of our sites

00:43:36.809 --> 00:43:40.019
regulate gas pressure. If you do not regulate your

00:43:40.030 --> 00:43:42.989
gas pressure of heat or insulation around the downstream

00:43:43.000 --> 00:43:47.039
side, you could form ice in the, in the reduction valves

00:43:47.050 --> 00:43:49.579
When you take the pressure out of the, out of the,

00:43:49.590 --> 00:43:52.688
out of the gas, I mentioned the combustion terminal

00:43:52.800 --> 00:43:56.128
in the fillers, chemicals really easy to forget your

00:43:56.139 --> 00:43:58.570
caustic tanks that you need to treat your chemical

00:43:58.708 --> 00:44:01.280
boiler chemistry with your acid tanks. You need to

00:44:01.289 --> 00:44:04.250
treat your chemistry inside your, your coin towers

00:44:04.378 --> 00:44:06.500
These are things that go above and beyond the procedures

00:44:06.510 --> 00:44:08.628
that we've looked at based on our experience across

00:44:08.639 --> 00:44:11.349
the country, you know, we operate in all the different

00:44:11.360 --> 00:44:12.769
areas of the country. So these are all the things that

00:44:12.780 --> 00:44:16.059
we've brought into our op procedure and our standardization

00:44:16.070 --> 00:44:19.860
and, and the last but not least sampling on the stack

00:44:20.208 --> 00:44:22.659
the umbilical cords where we take sack samples off

00:44:23.269 --> 00:44:26.208
high winds will drive the heat out of that unit and

00:44:26.219 --> 00:44:28.340
these units do have moisture in them. The exhaust gas

00:44:28.349 --> 00:44:31.750
coming off the hers stacks, it will freeze. So we've

00:44:31.760 --> 00:44:34.820
gone back and looked at shielding or upgrading the

00:44:35.070 --> 00:44:37.929
heating elements inside the Cial umbilical cords to

00:44:37.938 --> 00:44:40.559
make sure. So that's just a few examples that I just

00:44:40.570 --> 00:44:42.639
jotted down. I wanted to just bring to the attention

00:44:42.648 --> 00:44:46.320
of this commission just to understand that, you know

00:44:46.329 --> 00:44:48.659
winterization takes on a much bigger life than if you

00:44:48.668 --> 00:44:51.148
don't drive your experiences in, from a year in year

00:44:51.159 --> 00:44:54.728
out of driving different things that happen and have

00:44:54.739 --> 00:44:57.030
a best management program to incorporate that stuff

00:44:57.340 --> 00:44:59.918
in next year's plans. We're not going to get what we

00:44:59.929 --> 00:45:03.389
need to get through in this program. So the other thing

00:45:03.398 --> 00:45:06.699
I'll tell you in Texas, which is unique to Texas is

00:45:06.708 --> 00:45:10.119
the wind, right? We have to make sure in Texas that

00:45:10.128 --> 00:45:12.840
we have a cooling ability in the summertime, we list

00:45:12.849 --> 00:45:15.849
last summer was really severe as far as driving the

00:45:15.860 --> 00:45:19.280
heat. And we saw days over 100 degrees, 105 degrees

00:45:19.418 --> 00:45:22.769
115 degrees, a lot of plants, day in and day out. So

00:45:22.780 --> 00:45:25.228
you cannot build shelters for the winter around some

00:45:25.239 --> 00:45:28.679
equipment that would not impact the operation of your

00:45:28.688 --> 00:45:32.179
fleet during summertime operations. So we have gone

00:45:32.188 --> 00:45:35.728
to like many of our, our peers have, you know, temporary

00:45:35.739 --> 00:45:38.179
shelters and windbreaks, but one tip, I'll tell you

00:45:38.188 --> 00:45:41.208
that we learned the hard way was you can put temporary

00:45:41.219 --> 00:45:44.820
shelters up. Don't forget the floor. I will tell you

00:45:44.829 --> 00:45:46.719
that grading, you know, a lot of our instrumentation

00:45:46.728 --> 00:45:50.340
is up on grading the first year we did before Uri.

00:45:50.349 --> 00:45:52.510
You know, we saw 11 year that we had problems with

00:45:52.519 --> 00:45:55.148
the instrumentation on the drum. We had a very nice

00:45:55.159 --> 00:45:57.550
enclosure heaters up there. We forgot the wind and

00:45:57.559 --> 00:46:00.570
we forgot the floor. So now we put rubber mats out

00:46:00.579 --> 00:46:03.110
and make sure we're good to go. You know, everything's

00:46:03.119 --> 00:46:06.159
protected that way. So I just want to close and I know

00:46:06.168 --> 00:46:08.769
I have a limited amount of time, but we will be ready

00:46:08.780 --> 00:46:12.679
for attestation on December 1st. Once we finish our

00:46:12.688 --> 00:46:15.849
summer readiness plans, we immediately start into our

00:46:15.860 --> 00:46:18.110
winter readiness plans. It's just like running outages

00:46:18.119 --> 00:46:20.639
in a plant. You're never really done. Close one outage

00:46:20.648 --> 00:46:22.369
take the weekend off and start all over on the next

00:46:22.378 --> 00:46:26.139
the next plant. So we plan our annual winter readiness

00:46:26.148 --> 00:46:28.530
We start our Prew winter discussions and start looking

00:46:28.539 --> 00:46:31.329
at scopes in the May, June time for May July time frame

00:46:31.840 --> 00:46:34.050
Our, our final work scopes are really in the August

00:46:34.079 --> 00:46:36.489
September time frame just to get it ready for our fall

00:46:36.500 --> 00:46:39.849
outages. We take maintenance outages every fall the

00:46:39.860 --> 00:46:42.389
fall most but not in all of our units. And we do

00:46:42.398 --> 00:46:46.239
execute the work during that time, we update our operational

00:46:46.250 --> 00:46:48.280
procedures and the things that I just spoke about before

00:46:48.289 --> 00:46:50.579
This are operational procedures. These are things that

00:46:50.590 --> 00:46:53.000
could happen when you're maintaining the plan or you're

00:46:53.010 --> 00:46:54.820
getting ready for a storm. We want to make sure we

00:46:54.829 --> 00:46:56.688
have a procedure that we drill on and have everybody

00:46:56.699 --> 00:46:59.639
ready to go to. We conduct training that incorporates

00:46:59.648 --> 00:47:01.378
any of the new procedures that we developed from the

00:47:01.389 --> 00:47:04.398
year before in November. And then we go through the

00:47:04.409 --> 00:47:10.079
attestation process through December 1st as you and

00:47:10.090 --> 00:47:12.188
then we have a post meeting, follow up or a lessons

00:47:12.199 --> 00:47:14.829
learned meeting after that. Now, we will do additional

00:47:14.860 --> 00:47:17.369
tabletop drills or other things based on how we think

00:47:17.378 --> 00:47:19.820
the flow is going. Or if we have new leadership teams

00:47:19.829 --> 00:47:21.418
and plants, we'll make sure they're all trained up

00:47:21.429 --> 00:47:23.510
and ready to go. So for that, I thank you for the

00:47:23.519 --> 00:47:26.619
opportunity to present and, and uh if you want to ask

00:47:26.628 --> 00:47:30.409
any questions, thank you NRG. All right, good morning

00:47:30.418 --> 00:47:32.969
I appreciate the time here this morning. Uh My name

00:47:32.978 --> 00:47:35.728
is Roger Morgan. I'm the vice president of plant operations

00:47:35.739 --> 00:47:38.469
for the South region and International Assets for uh

00:47:38.478 --> 00:47:42.500
NRG. When I think about winter readiness with the,

00:47:42.510 --> 00:47:46.389
for NRG. Uh We start that process early in the year

00:47:46.458 --> 00:47:49.659
Uh It's uh to my peer to the love the cow and

00:47:49.668 --> 00:47:52.929
we start as early as June, we look at uh the winter

00:47:52.938 --> 00:47:55.478
readiness to be ready with the plants from November

00:47:55.489 --> 00:48:00.228
1st to March 31st and we have a very, uh, detailed

00:48:00.239 --> 00:48:03.280
procedure that we follow. Uh, we have a corporate procedure

00:48:03.289 --> 00:48:07.260
that's currently on revision 16, each one of the plants

00:48:07.269 --> 00:48:10.898
because they're all different in the style, the age

00:48:10.909 --> 00:48:14.139
and the type of units. Uh, they use that procedure

00:48:14.148 --> 00:48:17.208
that they are to adhere to, to develop a site, site

00:48:17.219 --> 00:48:21.739
specific procedure that they adhere to when we, uh

00:48:21.750 --> 00:48:24.398
get into the winter readiness. And we start in July

00:48:24.409 --> 00:48:26.719
1 of the things I'd like to note is uh after the

00:48:26.728 --> 00:48:30.500
winter storm Uri instrumentation and a lot of our critical

00:48:30.510 --> 00:48:33.760
piping, we found to be a very, very big challenge.

00:48:34.039 --> 00:48:37.699
Uh Some of our units are older units. Uh We actually

00:48:37.708 --> 00:48:41.039
went in and brought in uh our integer technical services

00:48:41.050 --> 00:48:43.840
Our, our engineering group brought in uh another engineering

00:48:43.849 --> 00:48:47.599
group and we literally stripped miles of piping at

00:48:47.610 --> 00:48:53.228
the plants, we redid all of the uh the heat, tracing

00:48:53.239 --> 00:48:56.878
the wrapping, the insulation. Uh We brought that into

00:48:56.889 --> 00:49:00.139
a control system that now feeds into the control room

00:49:00.148 --> 00:49:02.829
where the operators not only have real time vision

00:49:03.309 --> 00:49:06.478
of their control systems, but they also get alarmed

00:49:06.489 --> 00:49:09.349
if one of them starts dropping in temperature. Uh The

00:49:09.360 --> 00:49:12.139
unique thing about this, this process that we use now

00:49:12.148 --> 00:49:16.239
too. Um The electricians and I and C technicians love

00:49:16.250 --> 00:49:18.449
it because it makes it very easy for them to troubleshoot

00:49:18.458 --> 00:49:21.478
they'll tell them what line and where at. So it, it

00:49:21.489 --> 00:49:24.519
makes it a quick fix if we were to have or experience

00:49:24.530 --> 00:49:28.369
issues during a freeze. Even. Um, the, I think one

00:49:28.378 --> 00:49:31.958
of the, I, I consider a best practice for us is, uh

00:49:31.969 --> 00:49:35.239
is our lessons learned. Um, I've been in this business

00:49:35.250 --> 00:49:39.079
for 43 years. If your lessons learned in the funnel

00:49:39.360 --> 00:49:42.369
and your list isn't getting longer. You know, you got

00:49:42.378 --> 00:49:44.820
issues and, and I'm, and I'm very pleased to say our

00:49:44.829 --> 00:49:49.039
our, our lessons learned, this has grown much smaller

00:49:49.409 --> 00:49:52.938
Um We do start early in the year with our process.

00:49:53.269 --> 00:49:56.639
Uh We do do all the testing. Uh I would like to

00:49:56.648 --> 00:49:58.869
touch on the instrument there a little bit because

00:49:58.878 --> 00:50:02.688
uh that is the lifeline in a plane and it is very

00:50:02.699 --> 00:50:06.969
critical. You check your, your dryers, your, your heaters

00:50:06.978 --> 00:50:09.918
your dew points. What you have to remember is with

00:50:09.929 --> 00:50:13.219
these dew points, they're taking it up a certain footage

00:50:13.228 --> 00:50:17.250
away from the dryer. Now, you've got 200 ft of piping

00:50:17.260 --> 00:50:20.010
going to the back of the plant and there's dropout

00:50:20.019 --> 00:50:23.079
points. What we did is we had an engineering group

00:50:23.090 --> 00:50:26.780
come in and we designed low point drains and we actually

00:50:26.789 --> 00:50:30.500
have, each plant has a procedure with an initial from

00:50:30.510 --> 00:50:34.179
the operator who drains that every two hours. If we

00:50:34.188 --> 00:50:36.780
do see a note build up or getting moisture in that

00:50:36.789 --> 00:50:39.619
line, they increase the blowdown rate and we go back

00:50:39.628 --> 00:50:41.978
and start checking our desk and, and our dryer system

00:50:41.989 --> 00:50:45.000
to make sure it's functioning properly. One thing to

00:50:45.010 --> 00:50:47.449
note on that the two points do go back to the control

00:50:47.458 --> 00:50:51.208
room. Now, we do have alarm points on that. Uh As far

00:50:51.219 --> 00:50:55.289
as energy, uh, the lessons we learned in Uri really

00:50:55.300 --> 00:50:59.260
prompted us to step up our game in the winter readiness

00:50:59.269 --> 00:51:02.208
Uh I think we, uh, we thought we were really good before

00:51:02.800 --> 00:51:05.469
Uh I think now we're, we're much, much better and much

00:51:05.478 --> 00:51:08.090
better off and we will be ready to sign the attestation

00:51:08.099 --> 00:51:11.159
by November 15th. The one thing I will add that we

00:51:11.168 --> 00:51:14.030
also started doing is we do, uh my guys like to call

00:51:14.039 --> 00:51:17.208
it an internal validation versus an internal audit

00:51:17.219 --> 00:51:19.989
I put together a group every year of operators and

00:51:20.000 --> 00:51:23.250
maintenance guys and then I have a contract insulator

00:51:23.260 --> 00:51:27.148
comes in and we do pre inspections before the winter

00:51:27.159 --> 00:51:30.030
Each plant. These guys go to every one of our plants

00:51:30.429 --> 00:51:34.119
If they identify gaps, they'll give that to not only

00:51:34.128 --> 00:51:37.300
myself but the plant managers on their closing remarks

00:51:37.619 --> 00:51:40.699
and then we go back and we'll fix those and we also

00:51:40.708 --> 00:51:43.360
share that in our lessons learn. And then the last

00:51:43.369 --> 00:51:46.179
thing I think that uh helps us tremendously is the

00:51:46.188 --> 00:51:49.760
uh the validation now with the ERCOT inspections that

00:51:49.769 --> 00:51:52.780
has really stepped up and, and they go through in detail

00:51:52.789 --> 00:51:55.000
our work orders and check what we've done, what we

00:51:55.010 --> 00:51:57.360
say we've done and validate what we've done. So that's

00:51:57.708 --> 00:52:01.539
that's another layer of validation, of course. So I

00:52:01.550 --> 00:52:03.989
believe we're ready for the winter run and I appreciate

00:52:04.000 --> 00:52:06.708
the time this morning. Thank you, Luminant.

00:52:09.688 --> 00:52:11.989
Good morning commissioners, Ned Bonkowski, Vice President

00:52:12.000 --> 00:52:14.438
of Texas Regulatory Policy for Vista, which is the

00:52:14.449 --> 00:52:17.449
parent company of Luminant. Um I wanna thank you for

00:52:17.458 --> 00:52:19.510
the, the opportunity to speak this morning and thank

00:52:19.519 --> 00:52:22.699
Erica for the invitation. Um, and I know you've got

00:52:22.708 --> 00:52:25.260
a busy agenda today. So I'll uh I'll try to be as

00:52:25.269 --> 00:52:29.179
brief as possible. Um Just to hit the high points first

00:52:29.188 --> 00:52:33.019
Um We luminant is preparing and will be prepared for

00:52:33.030 --> 00:52:35.179
the winter. We're going through our processes. Now

00:52:35.188 --> 00:52:37.659
we'll talk a little bit about that. Uh Just a moment

00:52:37.679 --> 00:52:40.398
I I'll reiterate what some of our colleagues have said

00:52:40.510 --> 00:52:43.239
It's a year round process. It's an iterative process

00:52:43.389 --> 00:52:46.349
Um You know, where you're constantly taking in lessons

00:52:46.360 --> 00:52:49.159
learned and preparing, you know, basically as soon

00:52:49.168 --> 00:52:51.148
as one season ends, starting to prepare for the next

00:52:51.159 --> 00:52:55.159
iteration of that season, um We know the, the rules

00:52:55.168 --> 00:52:57.389
we know the current the commission's new rules, we

00:52:57.398 --> 00:53:02.030
follow the rules and we uh we will be ready. So, um

00:53:02.199 --> 00:53:05.590
quick background on Vstra, just for those that aren't

00:53:05.599 --> 00:53:11.360
familiar, uh We are the largest integrated uh competitive

00:53:11.369 --> 00:53:14.708
power producer and, and uh and retail supplier in the

00:53:14.719 --> 00:53:18.639
country. We operate in 20 different states and the

00:53:18.648 --> 00:53:21.360
district of Columbia, including all 66 of the seven

00:53:21.369 --> 00:53:24.719
competitive wholesale markets. We serve approximately

00:53:24.728 --> 00:53:27.208
4 million residential, commercial and industrial retail

00:53:27.219 --> 00:53:33.280
customers. Um And we operate a portfolio of about 37,000

00:53:33.289 --> 00:53:36.409
megawatts of generation across the, across the country

00:53:36.728 --> 00:53:41.559
About 18.5 gigawatts of that is dispatchable generation

00:53:41.570 --> 00:53:44.519
here in ERCOT. And that is of all different types.

00:53:44.530 --> 00:53:48.269
We've got, uh we've got nuclear and coal natural gas

00:53:48.579 --> 00:53:52.949
and uh one of, I'm not sure if it's still the largest

00:53:52.958 --> 00:53:56.260
battery in, in ERCOT, but we uh we operate all different

00:53:56.269 --> 00:53:56.599
types.

00:53:58.429 --> 00:54:02.708
Um Vista operates with a focus on reliability, affordability

00:54:02.719 --> 00:54:06.719
and sustainability and want to emphasize that reliability

00:54:06.728 --> 00:54:09.199
is the first in that, in that uh that list for a

00:54:09.208 --> 00:54:13.438
reason, we understand the importance of electricity

00:54:13.449 --> 00:54:16.849
to the state and we invest every year in reliability

00:54:16.860 --> 00:54:20.239
we put hundreds of millions of dollars into our maintenance

00:54:20.250 --> 00:54:24.369
cap X for our thermal fleet and that helps to make

00:54:24.378 --> 00:54:28.579
sure that it is in top shape and can operate both through

00:54:28.590 --> 00:54:30.280
the, through the season and over the long haul.

00:54:33.668 --> 00:54:36.079
And in addition, we also go through a comprehensive

00:54:36.090 --> 00:54:38.590
preparation process. That was what I was alluding to

00:54:38.599 --> 00:54:41.128
earlier and I go into a little bit more detail about

00:54:41.449 --> 00:54:44.079
um but that is a robust and cross functional process

00:54:44.090 --> 00:54:47.610
that our people take very seriously. So it's a little

00:54:47.619 --> 00:54:52.590
bit of a before during and after approach to uh specific

00:54:52.599 --> 00:54:56.289
events. So the before obviously is preparing for the

00:54:56.300 --> 00:55:00.188
each season and that starts with the planned maintenance

00:55:00.199 --> 00:55:02.369
activities at each plant in the winter that's usually

00:55:02.378 --> 00:55:05.829
starting in October. We, we're able to start taking

00:55:05.840 --> 00:55:08.010
work that allows us to start taking maintenance outages

00:55:08.019 --> 00:55:09.949
and do the things that we need to, you know, recover

00:55:09.958 --> 00:55:13.250
from the summer, prepare for the, the winter. But then

00:55:13.260 --> 00:55:15.458
we also take lessons learned that are captured following

00:55:15.469 --> 00:55:17.429
each season and those go into the planning for the

00:55:17.438 --> 00:55:19.769
next season. So that way, once we're doing the maintenance

00:55:19.780 --> 00:55:22.228
we're incorporating the lessons learned from from the

00:55:22.239 --> 00:55:27.340
prior time, specifically, as we go through that process

00:55:27.349 --> 00:55:32.550
in October, we also have some readiness checks that

00:55:32.559 --> 00:55:35.728
involves specifically reviewing our insulation heat

00:55:35.739 --> 00:55:39.849
trace functionality, the panel, the heat trace panel

00:55:39.860 --> 00:55:42.668
monitoring, ensuring that we have adequate supplies

00:55:42.679 --> 00:55:46.300
available and ensuring that all of the relevant people

00:55:46.309 --> 00:55:50.369
at our at our plants are have received the latest training

00:55:50.378 --> 00:55:52.590
that they need to have to be ready for the season.

00:55:53.809 --> 00:55:57.349
Uh We also have an annual winter readiness assessment

00:55:57.360 --> 00:56:00.550
process and that's performed at our various sites.

00:56:00.559 --> 00:56:04.659
And that's a cross functional review with assessment

00:56:04.668 --> 00:56:06.958
teams that include subject matter experts from different

00:56:06.969 --> 00:56:10.349
teams across the across the company. Uh That those

00:56:10.360 --> 00:56:12.989
usually kick off in late October, early November. Uh

00:56:13.000 --> 00:56:16.949
those and we select sites based on size and their uh

00:56:16.958 --> 00:56:20.820
their history operations areas of those assessments

00:56:20.829 --> 00:56:23.829
include state of the current winterization maintenance

00:56:23.840 --> 00:56:26.550
activities where those are in the process, review of

00:56:26.559 --> 00:56:28.820
lesson learned historical issues. And we do a plant

00:56:28.829 --> 00:56:31.398
walk down with spot checks on insulation, he trace

00:56:31.409 --> 00:56:34.949
monitoring and alarms, things like that. We also have

00:56:34.958 --> 00:56:37.099
a process to make sure that any open issues at that

00:56:37.110 --> 00:56:39.309
point in time are then track to completion ahead of

00:56:39.320 --> 00:56:42.909
the winter season. So we're big on checklists. Those

00:56:42.918 --> 00:56:45.619
are an important way to make sure that you're not leaving

00:56:45.628 --> 00:56:50.458
anything, anything, uh left open. And then we have

00:56:50.469 --> 00:56:52.219
our winter readiness meetings that are held in early

00:56:52.228 --> 00:56:55.110
November. That's a review with each plants with generation

00:56:55.119 --> 00:56:58.579
leadership and then that feeds into a leadership winter

00:56:58.590 --> 00:57:01.159
readiness meeting that we'll have in mid November where

00:57:01.168 --> 00:57:04.668
generation leadership will then review that with the

00:57:04.679 --> 00:57:06.579
executive leadership of the company, including our

00:57:06.590 --> 00:57:10.329
our chief executive officer, which is what culminates

00:57:10.340 --> 00:57:13.110
in the attestation that the commission will requires

00:57:13.119 --> 00:57:14.909
prior to December 1st of each year,

00:57:17.119 --> 00:57:20.300
we also continue moving from the before to the during

00:57:20.309 --> 00:57:23.659
So we have in season checks where we will continue

00:57:23.668 --> 00:57:26.639
to check on those those key functionalities. We also

00:57:26.648 --> 00:57:30.409
have monitoring processes and maintenance activities

00:57:30.418 --> 00:57:34.159
We have our Power Optimization Center which is a centralized

00:57:34.168 --> 00:57:37.760
location at our headquarters in Dallas where we have

00:57:37.769 --> 00:57:41.050
key information streamed in from all of our generation

00:57:41.059 --> 00:57:45.148
resources. So those can be monitored remotely by our

00:57:45.159 --> 00:57:48.820
operations and engineering teams and they can, you

00:57:48.829 --> 00:57:51.878
know, start working together and collaborate on addressing

00:57:51.889 --> 00:57:54.929
issues as if and when they do, they do come up help

00:57:54.938 --> 00:57:57.260
to minimize any issues and, and, and you know, make

00:57:57.269 --> 00:57:59.208
sure we've got all the brain power we we can muster

00:57:59.219 --> 00:58:04.728
to, to work on that um, at each plants. We also do

00:58:04.739 --> 00:58:07.570
have monitoring routines in addition to those remote

00:58:07.579 --> 00:58:11.320
monitoring capabilities. Um And, you know, we keep

00:58:11.329 --> 00:58:13.708
a focus on those cold weather critical components.

00:58:13.719 --> 00:58:16.550
So the critical heat trace circuits, transmitter cell

00:58:16.559 --> 00:58:19.570
temperatures, box temperatures, you know, instrumentation

00:58:19.579 --> 00:58:23.250
draining, making sure that, you know, any moisture

00:58:23.260 --> 00:58:27.228
accumulation is drained appropriately. Um And review

00:58:27.239 --> 00:58:30.208
any other equipment that's deemed critical in accordance

00:58:30.219 --> 00:58:32.128
with the commission's rule. There's a definition that's

00:58:32.139 --> 00:58:34.010
in there, which is uh helps to provide a bright line

00:58:34.019 --> 00:58:38.228
So we know exactly which ones are uh therefore uh compliance

00:58:38.599 --> 00:58:41.349
And then during the cold winter events, we will actually

00:58:41.360 --> 00:58:44.590
supplement staffing at our, at our plants just to make

00:58:44.599 --> 00:58:47.860
sure we have additional hands on deck. Um We, you know

00:58:47.869 --> 00:58:50.878
make sure that we're following safety preparations

00:58:50.889 --> 00:58:52.918
for that the safety of our people is very important

00:58:52.929 --> 00:58:56.369
So making sure that we've got walkways, you know, deiced

00:58:56.378 --> 00:58:59.728
and, and, you know, folks are able to operate, they

00:58:59.739 --> 00:59:04.329
move around safely. Um And then we also have procedures

00:59:04.340 --> 00:59:06.800
for putting in, in place temporary mitigation measures

00:59:06.809 --> 00:59:10.418
So that's like temporary windscreens when needed. Um

00:59:11.579 --> 00:59:14.728
The de icing and walkway safety prepositioning portable

00:59:14.739 --> 00:59:18.010
heaters, if you need those to help with specific issues

00:59:18.019 --> 00:59:20.889
draining any non critical water lines, make sure, you

00:59:20.969 --> 00:59:23.329
know, minimize risk of any freezing there. And then

00:59:23.340 --> 00:59:25.599
we also have regional warehouses that we can stage

00:59:25.610 --> 00:59:27.869
for fleet support, make sure we've got water treatment

00:59:27.878 --> 00:59:30.929
capabilities to move around the fleet as needed.

00:59:32.989 --> 00:59:35.989
And then throughout the event, we continue to remote

00:59:36.000 --> 00:59:39.110
remotely monitor from our Power optimization center

00:59:40.478 --> 00:59:45.289
We have at least daily calls where the fleet checks

00:59:45.300 --> 00:59:48.349
in. And can you share information, help to identify

00:59:48.360 --> 00:59:52.139
things that, that may need troubleshooting. And if

00:59:52.148 --> 00:59:54.418
and when necessary, we also can activate our emergency

00:59:54.429 --> 00:59:57.909
operations center which is has additional staffing

00:59:57.918 --> 01:00:01.708
and focus on making sure that we are able to operate

01:00:01.719 --> 01:00:05.489
at top levels through through events. So I will close

01:00:05.519 --> 01:00:07.500
there and thank you again for the time. Thank you,

01:00:08.849 --> 01:00:11.840
Julia. Great. Thank you. Good morning. Thank you, Chair

01:00:11.849 --> 01:00:15.099
Jackson commissioners. I'm Julia Harvey on behalf of

01:00:15.110 --> 01:00:18.378
Texas Electric Cooperative's, the Statewide Association

01:00:18.389 --> 01:00:20.938
of Electric Cooperative's happy to be here to talk

01:00:20.949 --> 01:00:24.099
talk about co op weatherization and winter preparedness

01:00:24.239 --> 01:00:27.688
I wanted to share kind of a high level overview from

01:00:27.699 --> 01:00:30.813
the association kind of stance. So if there are more

01:00:30.824 --> 01:00:33.534
kind of technical questions, I might have to, you know

01:00:33.543 --> 01:00:37.034
go back and ask the actual unit owners. But as you

01:00:37.043 --> 01:00:40.215
all know, we have facilities in in different circumstances

01:00:40.224 --> 01:00:43.985
from the panhandle to far south Texas, North Texas

01:00:43.994 --> 01:00:47.375
and the eastern portion of the state. And so like others

01:00:47.385 --> 01:00:50.864
co op facility owners have shifted their operations

01:00:50.945 --> 01:00:53.563
toward the winter season and they do that far in advance

01:00:53.574 --> 01:00:57.789
of the winter season. In particular, regarding weatherization

01:00:57.800 --> 01:01:01.429
similarly to my colleagues, we are in full compliance

01:01:01.438 --> 01:01:03.989
with the rule. We understand the rule. We've tested

01:01:04.000 --> 01:01:07.668
our critical components, particularly the heat tracing

01:01:07.679 --> 01:01:12.239
equipment. We've added enclosures, windbreaks, insulation

01:01:12.250 --> 01:01:15.349
brought in portable heaters that can be used out in

01:01:15.360 --> 01:01:18.000
the field should they be needed? You might have heard

01:01:18.010 --> 01:01:20.795
have heard about the the barrels of mesquite wood that

01:01:20.804 --> 01:01:23.516
can be burned on site to keep facilities functioning

01:01:23.755 --> 01:01:27.155
that even that is an option in extreme circumstances

01:01:27.304 --> 01:01:30.644
We've also done additional training of personnel regarding

01:01:30.655 --> 01:01:34.114
operations in winter weather and we're feasible where

01:01:34.125 --> 01:01:37.706
we're contractually feasible, co ops have firm fuel

01:01:37.715 --> 01:01:41.125
in place that said there's always the risk of force

01:01:41.135 --> 01:01:43.981
majeure. It doesn't matter how firm the contract is

01:01:44.001 --> 01:01:47.652
and that's kind of outside of our control a couple

01:01:47.661 --> 01:01:50.172
of other points. And I'll be very brief regarding our

01:01:50.181 --> 01:01:53.940
dual fuel capable units. Our owners have conducted

01:01:53.951 --> 01:01:56.740
an assessment of the dual fuel capability at those

01:01:56.751 --> 01:02:00.172
locations and so that will be in place for this season

01:02:00.471 --> 01:02:03.351
And then finally on the switch resources, the grid

01:02:03.362 --> 01:02:07.449
switchers, the operation of those is governed by the

01:02:07.458 --> 01:02:12.099
reliability coordinator RC to RC agreement. And so

01:02:12.110 --> 01:02:16.728
that dictates kind of which power region receives capacity

01:02:16.739 --> 01:02:19.289
from that unit. My understanding of that agreement

01:02:19.300 --> 01:02:22.909
is that the the grid switchers will be pointed into

01:02:23.079 --> 01:02:25.519
ERCOT this winter season or at least ERCOT will have

01:02:25.530 --> 01:02:29.309
first to the switch units this winter season. And so

01:02:29.320 --> 01:02:32.039
with that, that kind of summarizes a high-level Winter

01:02:32.050 --> 01:02:34.989
Posture on the generation side. Thank you. Thank you

01:02:35.148 --> 01:02:41.619
Julia and TPP. Sure with the Texas Public Power Association

01:02:41.728 --> 01:02:45.530
the Statewide Association for the Utilities. And I

01:02:45.539 --> 01:02:47.500
say this a lot, but it's worth repeating. One of the

01:02:47.510 --> 01:02:50.128
things I love about working for the MOUs and working

01:02:50.139 --> 01:02:53.059
with the MOUs is that I shop at the same grocery store

01:02:53.070 --> 01:02:57.648
as my utilities. GM. And he knows that and every one

01:02:57.659 --> 01:03:00.708
of our people from the smallest mo ou to, you know

01:03:00.719 --> 01:03:04.070
the Austins in San Antonio is no, regardless of what

01:03:04.079 --> 01:03:06.300
they might get from you. If they're gonna survive A

01:03:06.309 --> 01:03:09.349
L 12, the grocery store, they gotta get it right. And

01:03:09.360 --> 01:03:12.438
so generation transmission distribution as well. We're

01:03:12.449 --> 01:03:14.688
working to make sure that we are ready as much as we

01:03:14.699 --> 01:03:18.458
possibly can be for this winter storm where winter

01:03:18.469 --> 01:03:21.889
weather, not winter storm. Sorry, I didn't wanna, I

01:03:21.898 --> 01:03:24.269
do not want to put that out there. Um

01:03:25.829 --> 01:03:29.000
And so we're doing uh all the same stuff that my friends

01:03:29.010 --> 01:03:31.679
here are doing more, training, more infrastructure

01:03:31.688 --> 01:03:35.159
development and uh we're doing everything we can to

01:03:35.168 --> 01:03:37.539
get ready. I did want to mention that we do have two

01:03:37.668 --> 01:03:40.579
senior executives from CPS Energy, both on the generation

01:03:40.590 --> 01:03:42.938
side and the transmission side. You can talk through

01:03:42.949 --> 01:03:46.360
their specific things and specific preparation measures

01:03:46.369 --> 01:03:49.168
if you'd like to talk through those. But otherwise

01:03:49.179 --> 01:03:52.938
we feel good. We're, we'll be ready. Thank you. Thank

01:03:52.949 --> 01:03:55.090
you. That's the end of this panel, any questions

01:03:56.648 --> 01:04:00.228
madam chair, if I may and and this this could be for

01:04:00.239 --> 01:04:02.019
the group, I know some of you will not be able to

01:04:02.030 --> 01:04:07.958
answer in as specific a way as possible. But for, for

01:04:07.969 --> 01:04:08.179
our IOU

01:04:10.269 --> 01:04:16.289
for our investor owned power providers, we we now have

01:04:16.300 --> 01:04:19.409
two years of experience under our belt with new weatherization

01:04:19.418 --> 01:04:23.059
standards and a new weatherization regime in the ERCOT

01:04:23.070 --> 01:04:26.688
system. I would assume that you as operators have seen

01:04:26.699 --> 01:04:30.199
some type of marked improvement or you have goals for

01:04:30.208 --> 01:04:33.780
your own systems, your own facilities on a year by

01:04:33.789 --> 01:04:34.878
year basis.

01:04:36.760 --> 01:04:40.280
It's going to be very important for this season considering

01:04:40.289 --> 01:04:44.300
the demand growth in the ERCOT system that during those

01:04:44.309 --> 01:04:48.510
periods of low intermittent output, low solar conditions

01:04:48.519 --> 01:04:54.340
which ERCOT has identified that one forced outage could

01:04:54.349 --> 01:04:57.510
be decisive for the system. It may be under certain

01:04:57.519 --> 01:05:01.938
conditions. So as you manage your teams, as you manage

01:05:01.949 --> 01:05:05.090
your facilities, what type of improvement on a year

01:05:05.099 --> 01:05:08.030
to year basis? Given the enhancements that you're making

01:05:08.039 --> 01:05:11.418
to your facilities, do you look for on a percentage

01:05:11.429 --> 01:05:16.860
basis? Do you look for a 2% 5% 10% decline in forced

01:05:16.889 --> 01:05:22.309
outage rates that are based on a weather event on a

01:05:22.320 --> 01:05:24.909
year to year basis or what does success mean to you

01:05:24.918 --> 01:05:26.438
What does improvement mean to you?

01:05:30.340 --> 01:05:35.280
Well, for NRG what I I look back over the years and

01:05:35.289 --> 01:05:37.438
went back all the way to the farthest I could get back

01:05:37.449 --> 01:05:41.239
was 96. And I looked at the trip events with about

01:05:41.250 --> 01:05:44.628
the same size portfolio as we have. Now as far as megawatts

01:05:45.280 --> 01:05:49.728
and those events went from in 96 digit double digit

01:05:49.739 --> 01:05:54.228
numbers to single in the area event, you know, success

01:05:54.239 --> 01:05:58.599
to me is that we get through any type of winter event

01:05:58.949 --> 01:06:03.389
with zero D rates and zero forced events. We want to

01:06:03.398 --> 01:06:05.869
make sure that when we go into the winter ready, you

01:06:05.878 --> 01:06:10.398
know, process that if, if we have issues going into

01:06:10.409 --> 01:06:13.079
the sys, you know, to uh an event, we want to make

01:06:13.090 --> 01:06:17.438
sure we address those. We we've even run with extended

01:06:17.449 --> 01:06:20.628
tube leaks and just bought more water to get through

01:06:20.639 --> 01:06:22.570
to, you know, to make sure we make it through that

01:06:22.579 --> 01:06:26.909
event. So for me, Michael is zero events through the

01:06:26.918 --> 01:06:29.889
through through any type of event that we have to.

01:06:29.898 --> 01:06:33.360
But a realistic expectation, what do you think? Realistic

01:06:33.369 --> 01:06:34.148
I think

01:06:35.949 --> 01:06:39.168
realistically it depends on the the wind chill factor

01:06:39.179 --> 01:06:43.000
and the precipitation, right? So if you get precipitation

01:06:43.530 --> 01:06:46.889
that really compounds the issue, so it's really dependent

01:06:46.898 --> 01:06:52.269
on your insulation in your, your freeze protection

01:06:52.280 --> 01:06:56.119
circuits and how they're working. I I think realistically

01:06:56.128 --> 01:06:58.969
if you stay in the ones or twos on a forced event

01:06:59.369 --> 01:07:01.989
you're in pretty good shape. But, you know, again,

01:07:02.000 --> 01:07:05.010
the goal is zero more than I had yesterday. Thank you

01:07:05.019 --> 01:07:10.809
sir. I mean, our ultimate goal is event free operation

01:07:10.820 --> 01:07:13.969
So I think if you go back and look at our performance

01:07:13.978 --> 01:07:16.208
this summer as an overall fleet in Texas, you'll see

01:07:16.219 --> 01:07:20.239
our commitment to be available all the time. If you

01:07:20.250 --> 01:07:22.570
go back and look at our performance at the last winter

01:07:22.619 --> 01:07:26.269
storm at Elliott, we had problems at two plants,

01:07:28.159 --> 01:07:30.398
but one of them was a piece of heat trace that we

01:07:30.409 --> 01:07:32.179
tested the week before that failed. So you're gonna

01:07:32.188 --> 01:07:36.039
have some events but they're remediated very, very

01:07:36.050 --> 01:07:39.269
quickly, right? You can get to what's there, bypass

01:07:39.280 --> 01:07:40.898
the instrument, do whatever you need to do to make

01:07:40.909 --> 01:07:43.219
sure you get it back on. And then there's always going

01:07:43.228 --> 01:07:45.550
to be things like that, as you're saying, no matter

01:07:45.559 --> 01:07:48.679
how rigorous your plans are, are in a realistic world

01:07:49.438 --> 01:07:52.208
The, the, the events that we're concerned about is

01:07:52.219 --> 01:07:55.208
not so much tied to the winter storm. It is just the

01:07:55.219 --> 01:07:58.228
natural event of a plant going off at any given time

01:07:58.958 --> 01:08:02.099
You know, if you think about it, there's 30 40,000

01:08:03.280 --> 01:08:07.550
controls and control cards and devices, any one of

01:08:07.559 --> 01:08:10.010
them that could affect your operation of your plant

01:08:10.019 --> 01:08:13.159
Now, sometimes it's more severe than others. So you

01:08:13.168 --> 01:08:16.739
have to start with your average normalized forced outage

01:08:16.750 --> 01:08:20.929
rate force out factor. Now, if you look at our fleet

01:08:20.938 --> 01:08:24.028
we have progressively improved over the last several

01:08:24.038 --> 01:08:27.038
years and we'll continue to invest money and invest

01:08:27.047 --> 01:08:31.578
programs and improve that process. I think we all have

01:08:31.587 --> 01:08:34.528
to be honest that we've seen things happening. We had

01:08:34.538 --> 01:08:36.547
a transformer failure this summer, which we just did

01:08:36.559 --> 01:08:40.119
not predict and go back and look at some of those things

01:08:40.128 --> 01:08:43.560
You have to go back and see we had 50 60 days

01:08:43.569 --> 01:08:46.548
without rain and we started seeing build up on bushings

01:08:46.560 --> 01:08:50.239
and that we didn't see, you know, all of our utility

01:08:50.850 --> 01:08:54.149
colleagues had go clean lines in certain areas of the

01:08:54.159 --> 01:08:57.409
state to maintain it because we start seeing, you know

01:08:57.418 --> 01:09:00.750
arching across different phases. So there's always

01:09:00.759 --> 01:09:02.789
going to be, I mean, I would love to sit here and

01:09:02.798 --> 01:09:05.838
tell you a zero. I think, you know, it's probably a

01:09:05.850 --> 01:09:08.079
couple percent because I don't think you're fighting

01:09:08.088 --> 01:09:10.750
not only the winner, you're fighting the same demons

01:09:10.759 --> 01:09:12.470
you fight every day as far as keeping your points.

01:09:14.189 --> 01:09:16.168
That's the most honest answer I can give you. Yeah

01:09:16.180 --> 01:09:19.119
And that's why I ask. I always just as a regulator

01:09:19.128 --> 01:09:22.229
I'm looking at a base case, which is your normal maintenance

01:09:22.239 --> 01:09:25.569
level outage and your normal forced outage conditions

01:09:25.579 --> 01:09:28.520
which will happen. And then what's the weather effect

01:09:28.529 --> 01:09:31.289
And again, for the purposes of this winter, that cold

01:09:31.298 --> 01:09:33.668
weather factor, you know, that metal doesn't like cold

01:09:33.720 --> 01:09:36.819
as much as it does warmth and something's going to

01:09:36.829 --> 01:09:40.539
happen. So, but it sounds like you, you, you folks

01:09:40.548 --> 01:09:42.989
are taking steps, you're complying with standards,

01:09:43.000 --> 01:09:45.180
you're certifying, you're, you're making investments

01:09:45.189 --> 01:09:47.640
the market is rewarding you theoretically there is

01:09:47.649 --> 01:09:51.039
an alignment of interest that's going on. And, uh,

01:09:51.199 --> 01:09:53.640
and so as regulators over time, we just want to see

01:09:53.649 --> 01:09:56.838
marked improvement in terms of mechanical performance

01:09:56.850 --> 01:09:58.850
of the system. And as you heard, everybody say it's

01:09:58.859 --> 01:10:02.140
not set it and forget it you don't see on December

01:10:02.149 --> 01:10:05.409
1st, I'm good in May, you know, you have to keep the

01:10:05.418 --> 01:10:06.739
maintenance going the whole time

01:10:08.390 --> 01:10:11.489
commissioner if I may, I want to do what you said right

01:10:11.500 --> 01:10:13.439
there. And you know, there is an alignment of interest

01:10:13.449 --> 01:10:16.890
something that we, we watch closely is commercial availability

01:10:16.899 --> 01:10:19.079
of our fleet. And that's, you know, making sure that

01:10:19.220 --> 01:10:22.859
we have, we are able to, every unit that is able to

01:10:22.869 --> 01:10:26.529
run or every unit is able to run when the commercial

01:10:26.539 --> 01:10:29.149
signal is there, when the price signal is there. And

01:10:29.159 --> 01:10:31.418
during a winter event, that's almost certainly going

01:10:31.430 --> 01:10:33.479
to be a time when the price signal is there. So not

01:10:33.489 --> 01:10:37.939
only is there a reliability imperative but also a financial

01:10:37.949 --> 01:10:40.189
imperative and that's something that's, that's very

01:10:40.579 --> 01:10:45.759
much so, it sounds like being available 24 7 different

01:10:45.770 --> 01:10:47.939
seasons have different challenges as we enter into

01:10:47.949 --> 01:10:48.789
the winter.

01:10:50.659 --> 01:10:55.000
The morning is a critical um time frame and potentially

01:10:55.009 --> 01:10:57.810
the evening when the solar is, you know, ramping up

01:10:57.819 --> 01:11:00.609
or ramping down. Is there anything different that you

01:11:00.619 --> 01:11:03.588
do for the winter in terms of preparation for, for

01:11:03.600 --> 01:11:07.899
being available during those critical hours? Specifically

01:11:09.759 --> 01:11:12.789
I can, I can speak to some, just an observation. And

01:11:12.798 --> 01:11:14.838
I've noticed this is, this happens both in the winter

01:11:14.850 --> 01:11:16.909
and the summer is there, there is a tendency across

01:11:16.918 --> 01:11:20.100
the entire fleet where folks will usually start up

01:11:20.109 --> 01:11:23.458
and run through the night, even if that's, sometimes

01:11:23.470 --> 01:11:27.588
that's not what the, you know, was right then, but

01:11:27.600 --> 01:11:29.859
you reduce the, you know, start up risk. And so that

01:11:29.869 --> 01:11:31.869
helps ensure that you have units that are available

01:11:31.878 --> 01:11:32.489
for that week.

01:11:34.939 --> 01:11:37.668
We talked a lot about operational integrity, right

01:11:37.680 --> 01:11:41.189
And so, uh and you know, the need to, you know, have

01:11:41.199 --> 01:11:44.539
generation available, not just during the winter weather

01:11:44.548 --> 01:11:48.000
but on, on an ongoing basis. And I was just kind of

01:11:48.009 --> 01:11:52.399
interested in kind of your thoughts on redundancy.

01:11:52.819 --> 01:11:55.720
And, you know, is that an opportunity moving forward

01:11:55.930 --> 01:12:00.649
um in, in terms of, you know, plant design and, and

01:12:00.659 --> 01:12:03.619
what we're able to do, not necessarily just with a

01:12:03.628 --> 01:12:06.489
new facility, but with some of our aging infrastructure

01:12:06.500 --> 01:12:10.918
to, to enhance its overall ability to stay online,

01:12:15.350 --> 01:12:18.338
I will say this, I mean, I'm sure we don't have a

01:12:18.350 --> 01:12:23.649
position on it. Uh even in the older plants, you'll

01:12:23.659 --> 01:12:27.458
find that there are redundancy, there are very limited

01:12:27.470 --> 01:12:31.220
single point of failures in plants. The challenge becomes

01:12:31.229 --> 01:12:36.560
is does it that that redundancy become ADER rate or

01:12:36.569 --> 01:12:40.409
does it become an event? Right. So when we lose redundancy

01:12:40.418 --> 01:12:44.548
we go, we, we work back separate to get it back. One

01:12:44.560 --> 01:12:48.020
is either it's because it's ad rate or two because

01:12:48.029 --> 01:12:49.979
you're at that single point of failure and if the next

01:12:49.989 --> 01:12:53.838
piece fails then you're off. So there is a lot of redundancy

01:12:53.850 --> 01:12:57.060
in the plants. Now, even most of the new ones have

01:12:57.069 --> 01:13:01.039
a lot of redundancy. Like, uh, your newer CTS, uh,

01:13:01.048 --> 01:13:04.168
instead of two thermocouple, one fails you trip. Now

01:13:04.180 --> 01:13:06.750
they've got three, it takes two out of the three. So

01:13:07.100 --> 01:13:10.020
there's, that system is more robust than the older

01:13:10.029 --> 01:13:13.739
system, but there are redundancies in most plants on

01:13:13.750 --> 01:13:16.909
most. There's very, very, I, I I'm sitting here trying

01:13:16.918 --> 01:13:19.628
to think of all my plants. I can't think of many plants

01:13:19.640 --> 01:13:21.668
that don't that have single points of failure.

01:13:24.430 --> 01:13:27.579
So maybe this is a question for the outage scheduler

01:13:27.588 --> 01:13:31.668
portion of our agenda today. But one area of interest

01:13:31.680 --> 01:13:35.270
to me is as we're entering, you know, you know, preparation

01:13:35.279 --> 01:13:39.569
for the winter and um you need to take your plan generation

01:13:39.579 --> 01:13:42.329
outages because the plants ran really hard this summer

01:13:42.338 --> 01:13:46.699
We had extreme heat, um high electricity demand and

01:13:46.708 --> 01:13:50.259
it's important that the plants have an opportunity

01:13:50.270 --> 01:13:52.569
to do their planned maintenance outage and, and you

01:13:52.579 --> 01:13:55.458
know, ERCOT has their MD RPOC that seems to be trending

01:13:55.470 --> 01:14:02.140
well, um to provide those opportunities. Um but you

01:14:02.149 --> 01:14:04.939
know, the reality is as we enter into, deeper into

01:14:04.949 --> 01:14:06.939
getting close to the winter, there is, you know, the

01:14:06.949 --> 01:14:09.798
planned maintenance outages um with potentials for

01:14:09.810 --> 01:14:15.338
cancellation due to OCNS and A ANS um and also weatherization

01:14:15.350 --> 01:14:17.759
inspections. So there's a lot going on at your plant

01:14:17.770 --> 01:14:22.588
sites and I just wanna make sure that that's all going

01:14:22.600 --> 01:14:25.649
to work out from a planned generation outage standpoint

01:14:26.470 --> 01:14:31.310
I mean, I, I just, the preparation for winter and the

01:14:31.319 --> 01:14:34.759
preparation for summer, the windows that we get to

01:14:34.770 --> 01:14:39.569
maintain the plants get smaller each year. And it's

01:14:39.579 --> 01:14:43.970
not only in ERCOT, it's across the entire United States

01:14:44.909 --> 01:14:47.239
that strain of everybody narrowing everything down

01:14:47.250 --> 01:14:50.439
to essentially a 90 day period in the spring and the

01:14:50.449 --> 01:14:56.418
fall is straining the industry. So your crews for,

01:14:56.930 --> 01:14:58.649
if you go talk to seams and they'll tell you, they

01:14:58.659 --> 01:15:02.009
have 100 and 20 outage crews ready to work on combustion

01:15:02.020 --> 01:15:05.069
turbines. They're strained. They're gonna need more

01:15:05.128 --> 01:15:08.430
than that. The, the redundancy piece is, you know,

01:15:08.439 --> 01:15:12.890
is very much like, like was explained. But the, the

01:15:12.899 --> 01:15:15.378
time for redundancies, if you do have a failure of

01:15:15.390 --> 01:15:19.939
getting equipment back is now changed. So we've all

01:15:19.949 --> 01:15:22.569
had to change. Everybody on this table has had to change

01:15:23.229 --> 01:15:26.319
the way we do our maintenance and the way we plan our

01:15:26.329 --> 01:15:30.298
spares because a feed pump that would take you six

01:15:30.310 --> 01:15:34.520
weeks to get back now may take you nine months or 10

01:15:34.529 --> 01:15:38.279
months or 12 months. You know, the transformer that

01:15:38.289 --> 01:15:41.199
fails, that you could get in, you know, a year is now

01:15:41.208 --> 01:15:46.048
40 months, 42 months. So we've had to change everything

01:15:46.060 --> 01:15:48.939
the way we look at our maintenance strategies that

01:15:48.949 --> 01:15:51.329
we've been doing for years successfully. You know,

01:15:51.338 --> 01:15:54.970
with the, you know, we never ran to planned destruction

01:15:54.979 --> 01:15:57.298
We always had condition based maintenance programs

01:15:57.310 --> 01:16:00.180
throughout all of our programs. It's the best, most

01:16:00.189 --> 01:16:02.430
effective way to maintain your fleet, but you've now

01:16:02.439 --> 01:16:05.029
had to go back and add different things in there because

01:16:05.399 --> 01:16:07.439
condition based maintenance where you can get a unit

01:16:07.449 --> 01:16:10.909
back out. And if you take it out in September and have

01:16:10.918 --> 01:16:13.369
it back by December 1st for your winter reliability

01:16:13.378 --> 01:16:16.479
rooms, you can't do that anymore. Are you stacking

01:16:16.489 --> 01:16:19.619
inventory, replacement equipment going back? You have

01:16:19.628 --> 01:16:22.500
to start stacking inventory. So if you have a, if you

01:16:22.509 --> 01:16:25.850
have a two by one fleet and you have 4 ft pumps

01:16:25.859 --> 01:16:29.470
in, you know, then they're all 100% pumps, you essentially

01:16:29.479 --> 01:16:32.939
have two spares you can use and we've had to go back

01:16:32.949 --> 01:16:35.199
in and move a pump from one unit to another just to

01:16:35.208 --> 01:16:38.579
keep the spares going. And I think we're all doing

01:16:38.588 --> 01:16:41.430
the same things. I'm not, it's not, we're not unique

01:16:41.439 --> 01:16:44.430
in that situation. So the question, your question about

01:16:44.439 --> 01:16:46.829
outages, preparation and outage planning and your question

01:16:46.838 --> 01:16:49.619
about redundancies and re liabilities. The answers

01:16:49.628 --> 01:16:53.128
are, you know, it's getting harder and harder because

01:16:53.140 --> 01:16:55.270
everybody's trying to compress it into the same 90

01:16:55.279 --> 01:16:58.088
days. And we need to start getting awareness in that

01:16:58.100 --> 01:17:00.430
we're also sensitive to the fact that outage is being

01:17:00.439 --> 01:17:04.270
planned. Ok? You can have your outage starting on December

01:17:04.279 --> 01:17:07.409
15th of July. Well, our guys need a break too. Right

01:17:07.418 --> 01:17:09.759
So, we're working on our guys through Christmas and

01:17:09.770 --> 01:17:12.649
New Year holidays and they really up here has been

01:17:12.659 --> 01:17:14.520
doing this for a long time. You have a personal, so

01:17:14.600 --> 01:17:17.329
you've spent those Christmas days working, it means

01:17:17.338 --> 01:17:19.989
something to you. So, you know, these are the kind

01:17:20.000 --> 01:17:21.659
of things that we're dealing with now and we'll manage

01:17:21.668 --> 01:17:24.668
them, but they're all manageable. It just takes a different

01:17:24.680 --> 01:17:27.239
approach to how we do, do our day to day jobs. And

01:17:27.250 --> 01:17:29.909
that's all part of how we have to operate to make sure

01:17:29.918 --> 01:17:31.088
we're there when you need us,

01:17:32.668 --> 01:17:34.989
commissioner, if I can, if I can dovetail. And thank

01:17:35.000 --> 01:17:37.609
you for that question. I think it's, uh that's an important

01:17:37.619 --> 01:17:41.810
metric to keep a close eye on, uh to my knowledge,

01:17:41.819 --> 01:17:45.850
the, we have not yet hit the hard constraints of the

01:17:45.859 --> 01:17:49.520
MD RPOC, but there have been adjustments that have

01:17:49.529 --> 01:17:54.000
been made by, by all of our companies. I am aware of

01:17:54.009 --> 01:17:57.229
at least a few anecdotal instances where there looked

01:17:57.239 --> 01:17:58.949
like there would be a constraint and then it ended

01:17:58.958 --> 01:18:01.489
up, you know, easing up and you know, the plan maintenance

01:18:01.500 --> 01:18:03.548
ended up going through. So it didn't turn into a hard

01:18:03.560 --> 01:18:06.060
constraint. But there was, there have been times where

01:18:06.069 --> 01:18:10.579
there is an initial indication and, you know, I think

01:18:10.588 --> 01:18:14.109
the existence of the MDR PO and the, you know, the

01:18:14.119 --> 01:18:17.520
advanced the advanced action notices. The ans that

01:18:18.140 --> 01:18:22.119
ERCOT issues are, I like to refer to those as a canary

01:18:22.128 --> 01:18:25.659
in the coal mine signal for the, you know, resource

01:18:25.668 --> 01:18:28.548
adequacy. And you know, that's the work that the commission

01:18:28.560 --> 01:18:31.939
has been working very diligently on for, for years

01:18:31.949 --> 01:18:35.378
now. And you know, we fully support your efforts along

01:18:35.390 --> 01:18:38.009
those lines. You know, the n definition of resource

01:18:38.020 --> 01:18:40.588
adequacy is you have enough generation capacity to

01:18:40.600 --> 01:18:46.060
meet, you know, all load needs during as well in reasonably

01:18:46.069 --> 01:18:48.739
anticipated conditions while also taking into account

01:18:48.750 --> 01:18:51.609
reasonably anticipated, planned and unplanned outages

01:18:51.619 --> 01:18:57.609
of transmission and generation. And so, you know, when

01:18:57.619 --> 01:18:59.560
we have those constraints on those things that I think

01:18:59.569 --> 01:19:01.399
that just highlights the importance of the work that

01:19:01.409 --> 01:19:02.708
the commission is embarking on.

01:19:04.399 --> 01:19:07.159
Hey, one of the questions since they, they aren't gonna

01:19:07.168 --> 01:19:10.600
be up for the firm fuel supply service uh discussion

01:19:10.609 --> 01:19:13.579
but wanted to touch on the gas supply uh while we've

01:19:13.588 --> 01:19:17.319
got them. Uh ned, how's it looking? How did you, how

01:19:17.329 --> 01:19:19.779
did Vistra settle out in the auction? North Texas is

01:19:19.789 --> 01:19:25.458
important? Um You beefed up. I should probably, uh

01:19:25.470 --> 01:19:29.100
I should probably follow up with you directly on that

01:19:29.208 --> 01:19:33.289
Um as opposed to uh come in front of everyone, but

01:19:33.739 --> 01:19:37.970
uh you know, luminant is prepared and um we have invested

01:19:37.979 --> 01:19:42.159
significantly in our f fuel capabilities since winter

01:19:42.168 --> 01:19:46.259
storm Uri and that helps us provide additional reliability

01:19:46.270 --> 01:19:50.128
and resiliency. Awesome. And then NRG and Calpine similarly

01:19:50.140 --> 01:19:53.529
had access to more resources along the coast but also

01:19:54.069 --> 01:19:59.000
on site capabilities. How are you looking on fuel supply

01:20:00.009 --> 01:20:03.409
Not really my area to respond to. I can certainly get

01:20:03.418 --> 01:20:06.489
you the right response from the right person. But I

01:20:06.509 --> 01:20:08.779
I know that it's something that we take very seriously

01:20:08.789 --> 01:20:12.168
and we'll be able to test that we're ready to go. So

01:20:12.180 --> 01:20:15.208
I'll get you a different response. Yeah, I think it's

01:20:15.220 --> 01:20:18.750
helpful and, and you probably can have these conversations

01:20:18.759 --> 01:20:21.289
out in the open as is um I think ned mentioned for

01:20:21.298 --> 01:20:25.329
competitively sensitive um factor but um you know,

01:20:25.338 --> 01:20:28.458
understanding the gas availability, um aspect is very

01:20:28.470 --> 01:20:31.140
important. Also coal supply stacks. I know from time

01:20:31.149 --> 01:20:33.289
to time there have been impacts on there because of

01:20:33.439 --> 01:20:38.890
labor strikes and, and uh railway issues. Um you know

01:20:38.899 --> 01:20:41.250
dual fuel capability, the firm feels very important

01:20:41.259 --> 01:20:43.649
We're gonna have DaVita come up and talk to us. I know

01:20:43.659 --> 01:20:46.798
Julia, you mentioned your members have fuel oil capability

01:20:47.298 --> 01:20:49.708
Um that's all very important to touch on if y'all have

01:20:49.720 --> 01:20:51.930
anything to add after during that presentation. But

01:20:51.939 --> 01:20:55.319
it sounds like, you know, some of your companies have

01:20:55.329 --> 01:20:58.128
taken, you know, the steps to participate in firm fuel

01:20:58.458 --> 01:21:00.399
um product out there.

01:21:02.128 --> 01:21:04.048
I know we're going to move on to farm deal here really

01:21:04.060 --> 01:21:08.159
quickly, but I just had one last question and I apologize

01:21:08.168 --> 01:21:10.298
I was listening and maybe I just didn't hear it. But

01:21:10.350 --> 01:21:14.680
are you all ready Oh, yes, I thought I hit that first

01:21:14.689 --> 01:21:17.229
But yes, we we we are preparing and we will be ready

01:21:17.250 --> 01:21:21.100
Thank you. Thank you any more questions? No, thank

01:21:21.109 --> 01:21:24.750
you panel. Thank you so much. Next panel we are changing

01:21:24.759 --> 01:21:27.979
topics, firm fuel supply service and and

01:21:35.359 --> 01:21:35.539
yeah,

01:21:42.680 --> 01:21:43.069
it obviously.

01:21:50.970 --> 01:21:52.029
Yes. Yeah.

01:22:05.319 --> 01:22:05.350
Ok.

01:22:08.119 --> 01:22:08.869
You want to go ahead.

01:22:10.509 --> 01:22:12.798
Good morning chair Jackson and commissioners. Thank

01:22:12.810 --> 01:22:16.009
you for the opportunity to update you all regarding

01:22:16.020 --> 01:22:18.548
the results of the firm fuel supply procurement that

01:22:18.600 --> 01:22:22.159
ERCOT conducted for the next farm fuel supply season

01:22:22.168 --> 01:22:24.600
winter obligation period. Can you state your name and

01:22:24.609 --> 01:22:27.180
your, can you state your name? Yes, ma'am. My name

01:22:27.189 --> 01:22:29.609
is DaVita Dwyer and I'm a senior corporate counsel

01:22:29.619 --> 01:22:30.399
with ERCOT.

01:22:32.298 --> 01:22:34.939
As you all know, because you're intimately familiar

01:22:34.949 --> 01:22:37.739
with the service. Um This was a reliability service

01:22:37.750 --> 01:22:41.009
that was first implemented by your cot in 2022. It

01:22:41.020 --> 01:22:44.569
was the result of legislation from the 87th session

01:22:44.579 --> 01:22:48.399
in 2021 and also based on directives and and guidance

01:22:48.409 --> 01:22:51.000
that the commission provided to us including in the

01:22:51.009 --> 01:22:54.708
blueprint for wholesale electric market design. This

01:22:54.720 --> 01:22:58.048
service is designed to provide additional grid reliability

01:22:58.060 --> 01:23:01.109
and resilience during extreme cold weather conditions

01:23:01.470 --> 01:23:05.979
We compensate um Qses of qualified awarded generation

01:23:05.989 --> 01:23:10.220
resources that meet a higher fuel security and performance

01:23:10.229 --> 01:23:12.899
standard during the winter obligation period, which

01:23:12.909 --> 01:23:17.409
is defined as November 15th through March 15th. They

01:23:17.569 --> 01:23:20.409
um meet higher performance standards that include having

01:23:20.418 --> 01:23:24.829
reserved fuel and emissions allowances um to generate

01:23:24.838 --> 01:23:28.850
for up to 48 hours multiple times during the obligation

01:23:28.859 --> 01:23:32.600
period. Um Those um obligations also include ensuring

01:23:32.609 --> 01:23:35.779
that their fuel is maintained and their resources are

01:23:35.789 --> 01:23:38.789
prepared and able to come online and remain online

01:23:38.798 --> 01:23:41.890
if our dispatches them in the event of a natural gas

01:23:41.899 --> 01:23:44.439
curtailment or other fuel supply disruption for their

01:23:44.449 --> 01:23:50.838
unit payments are made um for each resources availability

01:23:50.850 --> 01:23:54.560
throughout the obligation period and those can be subject

01:23:54.569 --> 01:23:58.149
to clawback and or withholding for unavailability and

01:23:58.159 --> 01:24:02.239
or for performance issues under specified circumstances

01:24:02.250 --> 01:24:05.958
under the protocols. Um Payments may be made to refund

01:24:05.970 --> 01:24:10.020
refueling if an FFSS resource is dispatched during

01:24:10.029 --> 01:24:11.270
the obligation period.

01:24:14.140 --> 01:24:18.088
Thank you. As you all know, this service has been developed

01:24:18.100 --> 01:24:22.189
in phases. The first phase was um during the first

01:24:22.199 --> 01:24:25.600
obligation period, we have a list of the resources

01:24:25.609 --> 01:24:29.048
that were qualified for that first period. Two of the

01:24:29.060 --> 01:24:31.890
three were specified in the protocols and the third

01:24:31.899 --> 01:24:34.899
was based on guidance the commission gave us and the

01:24:34.909 --> 01:24:37.029
protocols specifically provide for the commission to

01:24:37.039 --> 01:24:41.079
have the flexibility to tell us um what other traits

01:24:41.088 --> 01:24:45.520
of resources should qualify for this next obligation

01:24:45.529 --> 01:24:49.039
period starting this November. Um The qualifications

01:24:49.048 --> 01:24:51.970
have been expanded again based on commission guidance

01:24:52.229 --> 01:24:54.759
Now, all of the currently qualified resources are in

01:24:54.770 --> 01:24:57.338
the protocols and those are listed here as well. The

01:24:57.350 --> 01:25:01.180
most significant expansion was to provide um eligibility

01:25:01.189 --> 01:25:04.369
for off-site natural gas resources that made additional

01:25:04.378 --> 01:25:07.628
um requirements that are focused on ensuring fuel availability

01:25:07.640 --> 01:25:10.810
in the event of a fuel supply disruption. Those include

01:25:10.819 --> 01:25:14.159
that they have to own the stored natural gas, they

01:25:14.168 --> 01:25:18.859
have to own or have a firm gas storage agreement for

01:25:18.869 --> 01:25:21.310
the storage of the natural gas. And they also have

01:25:21.319 --> 01:25:23.979
to have a firm transportation agreement on a qualifying

01:25:23.989 --> 01:25:26.829
pipeline. You'll notice that a lot of these terms in

01:25:26.838 --> 01:25:29.270
this slide are capitalized because they're defined

01:25:29.279 --> 01:25:32.850
terms in the protocols and provide more specificity

01:25:32.859 --> 01:25:36.088
as to what qualifies as things like a firm gas storage

01:25:36.100 --> 01:25:39.369
agreement or firm transportation agreement including

01:25:39.378 --> 01:25:43.569
having um necessary force majeure provisions in order

01:25:43.579 --> 01:25:46.279
to attempt to ensure that the resources get the fuel

01:25:46.289 --> 01:25:47.609
that they need when they need it.

01:25:50.680 --> 01:25:54.600
This slide summarizes and compares our first procurement

01:25:54.609 --> 01:25:57.819
for firm fuel supply service with this year's procurement

01:25:58.310 --> 01:26:01.140
um as you all have previously discussed in an open

01:26:01.149 --> 01:26:05.909
meeting, um We were able to procure more capacity for

01:26:05.918 --> 01:26:10.100
this next period at a lower cost based on y'all's guidance

01:26:10.109 --> 01:26:13.819
regarding the caps for the program. This also reflects

01:26:13.829 --> 01:26:17.140
that during the first um obligation period, we did

01:26:17.149 --> 01:26:20.739
actually end up having a fair amount of um clawbacks

01:26:20.750 --> 01:26:24.739
associated with availability and or a failure to come

01:26:24.750 --> 01:26:27.140
online or stay online during their deployment. And

01:26:27.149 --> 01:26:29.079
in that case, there was just one resource for which

01:26:29.088 --> 01:26:32.378
we had clawbacks for that. The others were for um unavailability

01:26:34.029 --> 01:26:37.048
and I'm happy to answer any questions you all have

01:26:37.060 --> 01:26:40.128
for the public we thought we'd provide useful links

01:26:40.338 --> 01:26:44.819
Um We have um all of the protocols, uh a web page

01:26:44.829 --> 01:26:46.810
that provides additional detailed information on the

01:26:46.819 --> 01:26:51.569
service and then also links to the four processes by

01:26:51.579 --> 01:26:54.909
which we have modified the protocols to introduce and

01:26:54.918 --> 01:26:56.569
then modify the service.

01:26:58.449 --> 01:27:00.779
DeVita. Th uh Thank you so much for all your help on

01:27:00.789 --> 01:27:03.509
this very important initiative to build this product

01:27:03.520 --> 01:27:05.708
to you and the RCO T team that worked on it. Um

01:27:05.720 --> 01:27:09.829
This has been um a tremendously useful product, beneficial

01:27:09.838 --> 01:27:13.140
product over the last couple of years and I look forward

01:27:13.149 --> 01:27:16.229
to being scaled up even more under the current framework

01:27:16.239 --> 01:27:18.819
we have out there. I I'm hopeful that we'll get more

01:27:18.829 --> 01:27:22.659
resources as we continue to um move forward with additional

01:27:22.668 --> 01:27:26.289
procurement in the future. Um You know, you noted,

01:27:26.298 --> 01:27:30.430
well that um you know, we saved um came in with less

01:27:30.439 --> 01:27:34.338
money um for less cost this for this procurement period

01:27:34.759 --> 01:27:36.909
And it seems like we've, we've fallen under the budget

01:27:36.918 --> 01:27:40.140
cap for both years, which the budget cap is 54 million

01:27:40.350 --> 01:27:44.909
Is that correct? That's right. Um We were able to procure

01:27:44.918 --> 01:27:49.220
every resource that was offered. Um We, we didn't have

01:27:49.229 --> 01:27:51.680
as many offers as would be necessary to exceed the

01:27:51.689 --> 01:27:56.140
budget cap. And you noticed that you, you noted that

01:27:56.149 --> 01:27:58.838
um some of the resources that didn't perform got pa

01:27:59.000 --> 01:28:01.890
clawbacks. Have there been any resources that have

01:28:01.899 --> 01:28:04.029
been removed from the program? Or have decided not

01:28:04.039 --> 01:28:07.208
to bid that were not complying with our products or

01:28:07.458 --> 01:28:10.149
with the FM fuel product. Yes, we published a list

01:28:10.159 --> 01:28:12.529
of all of the resources that have been awarded. And

01:28:12.539 --> 01:28:14.869
if you compare those lists, you'll see that there were

01:28:14.878 --> 01:28:17.310
some resources that were awarded last year and did

01:28:17.319 --> 01:28:21.359
not offer this year. Um Additionally, there were resources

01:28:21.369 --> 01:28:23.668
that were offered and awarded this year that didn't

01:28:23.680 --> 01:28:26.119
in the first. Mhm Thank you

01:28:27.918 --> 01:28:33.930
DaVita. So, from ERCOT S perspective, do we uh do we

01:28:33.939 --> 01:28:39.100
believe that capabilities are being enhanced on some

01:28:39.109 --> 01:28:42.220
of these facilities? So one of the observations from

01:28:42.229 --> 01:28:46.770
the results of the option was a expansion of on-site

01:28:46.779 --> 01:28:51.079
capabilities versus availing themselves of the phase

01:28:51.088 --> 01:28:56.470
two expansion in this round of procurement. And it

01:28:56.479 --> 01:29:00.989
it seems like there has been an expansion of capabilities

01:29:01.000 --> 01:29:05.470
over the last year. Is that ERCOT S observation or

01:29:05.479 --> 01:29:09.569
is that just me seeing something? I'm I'm not the best

01:29:09.579 --> 01:29:11.909
person to answer that question. Do you mind if I follow

01:29:11.918 --> 01:29:14.289
up with you on it? We always like to see if we

01:29:14.298 --> 01:29:17.449
actually have positive reactions to our market signals

01:29:17.458 --> 01:29:21.520
and it lets us know if we're on the right path, but

01:29:22.060 --> 01:29:24.350
I'm happy to take that as an action item and follow

01:29:24.359 --> 01:29:27.909
up with all of you with with the response. I see the

01:29:27.918 --> 01:29:28.470
wise

01:29:32.298 --> 01:29:33.140
sound a little.

01:29:35.088 --> 01:29:39.649
Yeah, Mark Patterson ERCOT, thank you. Um I would say

01:29:39.659 --> 01:29:43.628
a majority of the increase from this year. To last

01:29:43.640 --> 01:29:47.259
year is actually due to resources that were held back

01:29:47.270 --> 01:29:50.819
as alternate resources last year. OK. Offered in this

01:29:50.829 --> 01:29:54.689
year as a primary resource. So they finally committed

01:29:54.699 --> 01:29:57.949
It's not necessarily they installed new enhancements

01:29:57.958 --> 01:30:00.390
to their existing facilities, they were there, but

01:30:00.399 --> 01:30:02.689
now they felt comfortable to actually participate.

01:30:02.699 --> 01:30:03.770
That's the observation

01:30:06.369 --> 01:30:09.520
and Mark's appearance. Thank you for coming and helping

01:30:09.529 --> 01:30:13.029
Mark is a good prompt for me to note that this was

01:30:13.039 --> 01:30:16.359
a team effort by many divisions, many people at cotton

01:30:16.770 --> 01:30:20.819
So we wanted to note that, yeah, just from a commission

01:30:20.829 --> 01:30:22.869
perspective, I'd like to compliment ERCOT on this.

01:30:22.878 --> 01:30:25.899
We, we turned y'all into a chew toy from the commission's

01:30:25.909 --> 01:30:30.189
perspective and you reacted admirably to that and,

01:30:30.199 --> 01:30:34.119
and I think we had a great outcome from the proceeding

01:30:34.128 --> 01:30:39.708
So, thank you. Any other questions? No. OK. Thank you

01:30:39.720 --> 01:30:40.329
so much.

01:30:41.869 --> 01:30:45.239
Next panel is again, ERCOT and the topic is outage

01:30:45.250 --> 01:30:46.500
scheduler. Dan Woodfin

01:30:52.918 --> 01:30:57.579
didn't know you. I grew a little party. I did that

01:30:57.588 --> 01:30:57.659
too.

01:30:59.798 --> 01:31:03.989
Good morning. Can lift with her cut. Um We only have

01:31:04.000 --> 01:31:07.279
one slide this morning. And what this shows is the

01:31:07.600 --> 01:31:10.759
the MD R PUC that's been discussed, the maximum daily

01:31:10.770 --> 01:31:13.458
resource planned outage capacity. And so that's the

01:31:13.470 --> 01:31:17.000
the maximum amount of dispatchable non non-renewable

01:31:17.009 --> 01:31:20.600
generators that are allowed out based on some statistical

01:31:20.609 --> 01:31:27.979
analysis of wind load, forced outages. And so we set

01:31:27.989 --> 01:31:30.979
this uh starting a couple of years ago and then the

01:31:30.989 --> 01:31:34.949
so that's the blue line, it drops down somewhat precipitously

01:31:34.958 --> 01:31:37.000
there at first of December because there's certain

01:31:37.009 --> 01:31:40.029
elements of that calculation that are seasonal in nature

01:31:40.039 --> 01:31:42.838
And so as you switch over to the the from the fall

01:31:42.850 --> 01:31:46.048
season to the winter season, it drops off, uh the black

01:31:46.060 --> 01:31:51.329
line is the current uh aggregate approved outages of

01:31:51.338 --> 01:31:54.390
planned outages of those kind of uh generators, the

01:31:54.399 --> 01:31:56.970
non renewable generators. And you can see that it's

01:31:57.189 --> 01:32:00.259
pretty much this time of the first part of this is

01:32:00.270 --> 01:32:02.458
definitely the peak of outage season. It's bumping

01:32:02.470 --> 01:32:06.329
up against the the maximum for the next few weeks.

01:32:06.338 --> 01:32:09.259
Then there is some space that folks could take outages

01:32:09.270 --> 01:32:15.409
toward the mid to end of uh of uh November. We do

01:32:15.418 --> 01:32:19.699
allow some outages during the winter that tends to

01:32:19.708 --> 01:32:23.298
be private use networks and those kind of things that

01:32:23.310 --> 01:32:25.509
take advantage of that. For the most part, the other

01:32:25.520 --> 01:32:28.289
generators don't take advantage of planned generation

01:32:28.529 --> 01:32:30.930
I think the, the this seems to be working well. There

01:32:30.939 --> 01:32:36.418
is time. Uh if, if folks get uh aren't able to get

01:32:36.430 --> 01:32:39.000
the outages during this peak of the outage season,

01:32:39.009 --> 01:32:43.449
they could take them later in November. Um I want to

01:32:43.458 --> 01:32:47.069
echo the point that Ned made a while ago that as we

01:32:47.079 --> 01:32:51.310
continue to have this really to some extent over a

01:32:51.319 --> 01:32:53.720
long period of time, over the course of years will

01:32:53.729 --> 01:32:57.088
become uh plays into the resource adequacy question

01:32:57.100 --> 01:33:01.878
because you need to have sufficient dispatchable generation

01:33:02.039 --> 01:33:04.569
to cover the load. So if, if load continues to grow

01:33:04.579 --> 01:33:07.770
and dispatchable generation isn't added, then we will

01:33:07.779 --> 01:33:09.509
start having more conflicts here.

01:33:11.458 --> 01:33:13.229
And I think that's all I've got on that. Have you answer

01:33:13.289 --> 01:33:14.088
some questions,

01:33:16.000 --> 01:33:18.989
Dan, can you touch on the transmission plan? Uh the

01:33:19.000 --> 01:33:21.458
plan, transmission outage aspect. How are those trending

01:33:21.470 --> 01:33:24.378
How's that going? I know um Emily was gonna provide

01:33:24.390 --> 01:33:26.529
some comments and anybody else who wants to on that

01:33:26.539 --> 01:33:29.239
is welcome to do so. But I thought it would be helpful

01:33:29.250 --> 01:33:32.539
to understand how that's going. Yeah, so basically

01:33:32.548 --> 01:33:35.509
we haven't changed how we do transmission outages.

01:33:35.520 --> 01:33:42.119
As you know, we have, we evaluate about 150,000 transmission

01:33:42.128 --> 01:33:45.369
outages a year where all the transmission owners and

01:33:45.378 --> 01:33:48.470
and the generation outages are evaluated at every point

01:33:48.479 --> 01:33:51.199
in time to make sure there aren't conflicts that result

01:33:51.208 --> 01:33:54.739
in a reliability problem and that a lot of times uh

01:33:54.750 --> 01:33:57.350
some women will want to take an outage at this in this

01:33:57.359 --> 01:33:59.958
window and we ask them to move it to another window

01:33:59.970 --> 01:34:02.699
so that there's not a conflicting outage. We've seen

01:34:02.708 --> 01:34:05.500
the same company come in and request the outage on

01:34:05.509 --> 01:34:08.220
this end of a line and also request the outage on this

01:34:08.229 --> 01:34:10.329
end of the line. And if you're the guy in the middle

01:34:10.489 --> 01:34:12.779
you would, you would be out of service if both outages

01:34:12.789 --> 01:34:15.168
happen and we're trying to avoid those kind of things

01:34:15.489 --> 01:34:20.009
The uh we have uh summer outage restrictions. We talked

01:34:20.020 --> 01:34:23.878
about having winter outage restrictions as well on

01:34:23.890 --> 01:34:28.079
transmission that would limit the kind of outages that

01:34:28.088 --> 01:34:31.298
are taken to make sure that we're not having any outages

01:34:31.310 --> 01:34:35.259
that would, would cause uh generation be curtailed

01:34:35.270 --> 01:34:38.100
not be, not be able to be used during a, a real

01:34:38.109 --> 01:34:41.759
cold spill. Uh What we discovered is that really, we

01:34:41.770 --> 01:34:44.489
didn't need to do that. There was only one or two companies

01:34:44.500 --> 01:34:47.109
that were, were taking really extended outages and

01:34:47.119 --> 01:34:51.279
really, it's, it's all about can, if we see a wi winter

01:34:51.289 --> 01:34:54.079
coal spells are easier to see coming. You don't have

01:34:54.088 --> 01:34:57.359
an extended period, usually you'll have a few days

01:34:57.369 --> 01:35:00.479
and so we can see that winter uh coal spell coming

01:35:00.890 --> 01:35:03.600
and tell people that if they have got a restoration

01:35:03.609 --> 01:35:08.378
time, that's less than a week on those uh transmission

01:35:08.390 --> 01:35:11.649
outages, we can tell them, ok. Can you put this back

01:35:11.659 --> 01:35:16.208
In fact, this week when we issued the a, an uh we

01:35:16.220 --> 01:35:18.649
ask some transmission and some transmission owners

01:35:18.659 --> 01:35:20.270
did it on their own because they said we don't want

01:35:20.279 --> 01:35:22.649
to have this transmission line out and create a problem

01:35:22.659 --> 01:35:26.009
getting generation out of these plants. And so they

01:35:26.048 --> 01:35:28.529
if they have a short restoration time on these outages

01:35:28.539 --> 01:35:32.119
they can put it back. Um What we see is that there's

01:35:32.128 --> 01:35:34.189
there were one or two companies that took real, uh

01:35:34.199 --> 01:35:37.100
that were just basically bulldozing lines to, to re

01:35:37.259 --> 01:35:41.939
to re uh to upgrade them. And so they're out for months

01:35:42.048 --> 01:35:44.979
And uh but they were really an outlier, the rest of

01:35:44.989 --> 01:35:48.850
the companies don't do that. And so we uh the only

01:35:48.859 --> 01:35:51.628
change we've made to this process rather than putting

01:35:51.640 --> 01:35:54.548
winter outage restrictions on everybody was to try

01:35:54.560 --> 01:36:00.350
to cut back on approval of those uh long outages that

01:36:00.359 --> 01:36:03.329
also have a long restoration time. And so we wouldn't

01:36:03.338 --> 01:36:06.930
be able to put them back um follow if we see a

01:36:06.939 --> 01:36:09.789
cold spell coming. So really, that was the only difference

01:36:09.798 --> 01:36:12.588
and that was the lessons learned, lesson learned from

01:36:12.600 --> 01:36:16.798
the Mara winter event last year where we had some of

01:36:16.810 --> 01:36:19.539
those long outages that couldn't be put back even though

01:36:19.548 --> 01:36:23.729
we saw that ice storm coming. And uh we didn't want

01:36:23.739 --> 01:36:26.029
we had problems because of that. We didn't want it

01:36:26.039 --> 01:36:29.048
to happen again. But really, that's the only change

01:36:29.060 --> 01:36:31.680
we've made. Ok. Thank you so much.

01:36:34.789 --> 01:36:39.930
So, Dan, one of the things with MD RPOC, it um it's

01:36:39.939 --> 01:36:41.739
incredibly important because a lot of the different

01:36:41.750 --> 01:36:46.199
policies converge on the maintenance schedule that

01:36:46.279 --> 01:36:49.039
facilities wires companies are able to take in order

01:36:49.048 --> 01:36:52.838
to comply with a substantive rule as well as ERCOT

01:36:52.859 --> 01:36:57.310
protocol is there. Can, can you describe sort of the

01:36:57.668 --> 01:37:00.689
the system of sanity checks that goes into your decision

01:37:00.699 --> 01:37:04.359
to allow outage? And I and I look at it this way

01:37:05.619 --> 01:37:09.699
weatherization, mitigation, weatherization, inspections

01:37:09.708 --> 01:37:13.659
and mitigation procedures are going to be happening

01:37:13.668 --> 01:37:17.859
especially going into the winter in the midst of a

01:37:17.869 --> 01:37:20.918
hurricane season. Again, that doesn't end until November

01:37:21.220 --> 01:37:25.759
Different events can appear for the grid just like

01:37:25.770 --> 01:37:29.378
now, tomorrow will be an unseasonably warm day to where

01:37:29.390 --> 01:37:33.229
you're having to a, a call facilities back into service

01:37:34.180 --> 01:37:37.859
And so there needs to be some type of central coordinating

01:37:37.869 --> 01:37:41.088
structure within the ERCOT senior staff to determine

01:37:41.100 --> 01:37:43.798
it's like, all right, this facility just got hit by

01:37:43.810 --> 01:37:46.289
a hurricane. It needs to be ready for winter. It needs

01:37:46.298 --> 01:37:49.310
to come back in and make significant enhancements to

01:37:49.319 --> 01:37:53.079
its facility in order to be ready to comply. But it

01:37:53.088 --> 01:37:56.180
wasn't originally in the MDR. So I always kind of think

01:37:56.189 --> 01:37:58.439
about this like a football draft. You're lining up

01:37:58.449 --> 01:38:00.659
whoever your star players are and you're prioritizing

01:38:00.668 --> 01:38:04.649
who you're going to get in line and win. But um how

01:38:04.659 --> 01:38:07.878
do you guys make that determination? So a lot of the

01:38:07.890 --> 01:38:10.958
way we've got this set up is a lot of the uh

01:38:10.970 --> 01:38:14.708
is done by the generators themselves and that all this

01:38:14.720 --> 01:38:17.958
data is out there. And when they try to enter an outage

01:38:17.970 --> 01:38:21.039
if they see that they're over the limit, they can go

01:38:21.048 --> 01:38:24.259
look for another window. And so we don't actually turn

01:38:24.270 --> 01:38:27.529
it down necessarily, it's, it's self imposed looking

01:38:28.039 --> 01:38:31.810
for another slide. And in fact, these lines, although

01:38:31.819 --> 01:38:34.119
I cut it off at the end of this winter, it actually

01:38:34.128 --> 01:38:36.609
goes out, the data is out there for five years

01:38:38.529 --> 01:38:45.770
Dan, do you think um this new MD RPOC process has created

01:38:45.779 --> 01:38:48.119
more forced outages on the system or do you think it

01:38:48.128 --> 01:38:51.649
has minimized outages? Totally, we have seen forced

01:38:51.659 --> 01:38:54.470
outages going up. But I think it's to some extent what

01:38:54.479 --> 01:38:56.548
I think it was, the gentleman from Calpine talked about

01:38:56.560 --> 01:38:59.850
earlier that people have a planned outage that's in

01:38:59.859 --> 01:39:03.489
this window and then it takes them months longer to

01:39:03.500 --> 01:39:06.699
get their parts back than what it used to. And so they

01:39:06.708 --> 01:39:10.029
they may be, they may have more that, that planned

01:39:10.039 --> 01:39:13.140
outage may become a forced outage if it gets extended

01:39:13.239 --> 01:39:16.095
longer than what was originally intended. And so I

01:39:16.104 --> 01:39:18.475
don't know if it's this process as much as it is kind

01:39:18.484 --> 01:39:21.625
of the global supply shortage. I think it's something

01:39:21.833 --> 01:39:25.314
that we all need to keep looking at because a forced

01:39:25.324 --> 01:39:28.454
outage is a forced outage on the system and it wreaks

01:39:28.463 --> 01:39:31.634
havoc, you know, when we're in tight condition. So

01:39:31.753 --> 01:39:34.384
how much, how much notice do you get when that type

01:39:34.395 --> 01:39:36.904
of a condition exists where he wants to take his outage

01:39:36.914 --> 01:39:40.109
He's got the part in, he wants to install it. I mean

01:39:40.119 --> 01:39:43.470
does that catch you unawares or do you get lead time

01:39:43.479 --> 01:39:46.390
It's, it's usually more that they have a planned outage

01:39:46.399 --> 01:39:50.289
that gets extended longer. And so, and actually, if

01:39:50.298 --> 01:39:54.720
you look at my slides from the uh board meeting, you

01:39:54.729 --> 01:39:58.289
saw the force outages being fairly high in June and

01:39:58.298 --> 01:40:00.770
then they dropped off. And I think that's the phenomenon

01:40:00.779 --> 01:40:02.569
you're looking at there where you had planned outages

01:40:02.579 --> 01:40:03.890
that were supposed to be having in the spring that

01:40:03.899 --> 01:40:07.708
get extended into, into June because of delays in getting

01:40:07.720 --> 01:40:10.509
equipment. Is there another category that we should

01:40:10.520 --> 01:40:15.779
create on like, uh we just call it a planned outage

01:40:15.789 --> 01:40:18.310
and then a forced outage. Um

01:40:20.259 --> 01:40:24.588
This is my view is that a forced outage is an operating

01:40:24.600 --> 01:40:27.588
unit that trips during the day for some reason or has

01:40:27.600 --> 01:40:30.609
a boiler tube leak or something like that, that intra

01:40:30.619 --> 01:40:33.619
day has a challenge, but something that is planned

01:40:33.628 --> 01:40:36.279
and then can't come back online on schedule. Should

01:40:36.289 --> 01:40:38.548
we create another category for that? We actually have

01:40:38.560 --> 01:40:41.845
a lot more categories than just playing the enforced

01:40:41.854 --> 01:40:44.595
We have something that's called an unavoidable extension

01:40:44.604 --> 01:40:48.875
which is exactly that. And so we have more details

01:40:48.884 --> 01:40:52.293
We just typically bucket it into those two broad categories

01:40:52.305 --> 01:40:55.805
when we talk about it publicly. I've learned a lot

01:40:55.814 --> 01:40:57.814
over the last 2.5 years, but I've never heard of the

01:40:57.824 --> 01:41:01.185
unavoidable extension category now. So this is, this

01:41:01.194 --> 01:41:05.659
is good. Thank you. Yeah, to, to what extent and, and

01:41:05.668 --> 01:41:08.359
I know the prior panel touched on not only supply chain

01:41:08.369 --> 01:41:10.810
and time constraints but also labor constraints. So

01:41:10.819 --> 01:41:13.979
they hire contractors to come in and help with, um

01:41:14.029 --> 01:41:18.208
you know, planned maintenance. And do you guys talk

01:41:18.220 --> 01:41:20.609
to the generators? Like when, for instance, they've

01:41:20.619 --> 01:41:23.539
they've scheduled to do an outage, but there's an N

01:41:23.560 --> 01:41:25.939
A and they have to move it. But then their vendors

01:41:25.949 --> 01:41:28.259
you know, their contractors moved around. What is there

01:41:28.270 --> 01:41:30.479
a level of communication that happens at that, at that

01:41:30.489 --> 01:41:34.899
point? So there is, there is a lot of procedure around

01:41:34.909 --> 01:41:39.128
those A s and if we issue an A A and you've

01:41:39.140 --> 01:41:41.229
got a coal plant that's playing on taking an outage

01:41:41.239 --> 01:41:44.699
and you've got hundreds of people lined up to the generators

01:41:44.708 --> 01:41:48.708
can actually tell us no, you can't move that outage

01:41:48.720 --> 01:41:50.979
And so that's kind of the first line of defense there

01:41:51.289 --> 01:41:54.168
And then the second thing is we, we work with them

01:41:54.180 --> 01:41:58.109
to, if it is one that they allow us to uh, to

01:41:58.279 --> 01:42:02.899
cancel or, or, or move, uh, we work with them, uh kind

01:42:02.909 --> 01:42:06.838
of, uh, uh give them some priority around finding a

01:42:06.850 --> 01:42:09.829
slot to, to reschedule it when folks are available

01:42:10.100 --> 01:42:11.430
Ok. Thank you.

01:42:13.189 --> 01:42:16.509
Uh Commissioner. Did you want to let Emily say her

01:42:16.520 --> 01:42:22.619
piece? Um I think she's eager to, I mean, there was

01:42:22.628 --> 01:42:25.739
a reference to bulldozing construction methods that

01:42:25.750 --> 01:42:27.378
I think we don't want to leave on a, you want to

01:42:27.390 --> 01:42:28.569
define what that means.

01:42:32.588 --> 01:42:35.770
You, Emily, can you state your name? Yes, Emily Jolly

01:42:35.779 --> 01:42:39.949
with LC A Transmission Services Corporation. Um, as

01:42:39.958 --> 01:42:43.020
you all know, LCITSE is one of the largest T SPS transmission

01:42:43.029 --> 01:42:45.939
service providers in ERCOT. We own and operate over

01:42:45.949 --> 01:42:49.199
5400 circuit miles of transmission across the state

01:42:49.470 --> 01:42:54.378
and own equipment in 430 substations. Um Obviously

01:42:54.439 --> 01:42:58.270
ERCOT has long had plenary authority to review uh and

01:42:58.279 --> 01:43:04.329
then accept delay, reject transmission outages. Um

01:43:04.699 --> 01:43:07.609
In addition, the commission over the past several years

01:43:07.619 --> 01:43:10.750
working with ERCOT has imposed summer outage restrictions

01:43:11.159 --> 01:43:15.298
um which generally limit the type and duration of transmission

01:43:15.310 --> 01:43:18.909
facility outages that T SBS can take from mid May through

01:43:18.918 --> 01:43:23.289
mid-september as a result, the time period when TSP

01:43:23.298 --> 01:43:26.159
can perform their work is compressed into the other

01:43:26.168 --> 01:43:29.418
eight months of the year. And so we want to highlight

01:43:29.430 --> 01:43:31.668
that context as we have this discussion about some

01:43:31.680 --> 01:43:34.720
of the issues that Dan touched on. Um and we're seeing

01:43:34.729 --> 01:43:37.479
new challenges associated with obtaining outages now

01:43:37.489 --> 01:43:41.779
in the fall and winter months. So certain activities

01:43:41.789 --> 01:43:43.859
and and this isn't just maintenance, right? This is

01:43:43.869 --> 01:43:47.298
all of the um transmission line work associated with

01:43:47.310 --> 01:43:50.689
activity like storm hardening, um interconnecting new

01:43:50.699 --> 01:43:55.859
generation resources, capacity upgrades and other activities

01:43:55.869 --> 01:43:59.779
that directly increase resi reliability and resiliency

01:44:00.069 --> 01:44:02.699
um are becoming more difficult to timely complete.

01:44:03.319 --> 01:44:06.329
And in some instances, we're having to utilize more

01:44:06.338 --> 01:44:10.628
complex construction methods um like performing energized

01:44:10.640 --> 01:44:13.899
work work on energized facilities uh which will of

01:44:13.909 --> 01:44:16.869
course increase costs that consumers will ultimately

01:44:16.878 --> 01:44:22.220
bear. So with that context in mind, um we fully understand

01:44:22.239 --> 01:44:25.199
right, that ERCOT T needs to be able to adapt to changing

01:44:25.208 --> 01:44:28.750
conditions and ensure reliability. And in some cases

01:44:28.759 --> 01:44:32.399
they, this may mean withdrawing approved outages. Um

01:44:32.409 --> 01:44:35.289
But we do think that there are some ways that coordinations

01:44:35.298 --> 01:44:38.409
with ERCOT T can be improved. Uh And we like to have

01:44:38.418 --> 01:44:40.659
those discussions with the benefit of the commission's

01:44:40.668 --> 01:44:44.259
guidance. We also think it's important to ensure that

01:44:44.270 --> 01:44:48.229
T SPS are using the same study assumptions and inputs

01:44:48.239 --> 01:44:51.750
as ERCOT outage coordinators and that these assumptions

01:44:51.759 --> 01:44:55.539
are transparent and uh made available to all market

01:44:55.548 --> 01:44:58.259
participants. Um Cause obviously, we have a lot of

01:44:58.270 --> 01:45:00.819
different stakeholders that we're serving in this process

01:45:01.119 --> 01:45:03.259
Um And we don't want to be in the position of picking

01:45:03.270 --> 01:45:07.500
winners and losers. Um And that those inputs and assumptions

01:45:07.509 --> 01:45:10.289
are consistent with what's in the various binding documents

01:45:10.298 --> 01:45:13.329
I think that's another important piece of this, but

01:45:13.350 --> 01:45:17.298
primarily our concern is that given the conservative

01:45:17.310 --> 01:45:20.289
operating posture that we're seeing uh that this will

01:45:20.298 --> 01:45:23.329
result in a new set of seasonal restrictions and that

01:45:23.338 --> 01:45:26.970
will further compress us and lead to directly to higher

01:45:26.979 --> 01:45:31.789
costs for consumers. Um We do appreciate your attention

01:45:31.798 --> 01:45:34.560
to the issue and inviting me up to identify this. Uh

01:45:34.579 --> 01:45:36.564
We look forward to collaborating with the commission

01:45:36.574 --> 01:45:39.414
and the commission staff and of course ERCOT, to talk

01:45:39.423 --> 01:45:41.515
through these emerging operational challenges, I'm

01:45:41.524 --> 01:45:46.904
happy to take any questions. So Dan on that one, we

01:45:46.914 --> 01:45:49.595
have a window that we're trying to cover between new

01:45:49.604 --> 01:45:53.435
dispatchable generation being built closer to loads

01:45:53.444 --> 01:45:56.753
theoretically, which may help on a number of policy

01:45:56.765 --> 01:46:01.100
fronts, physical and market driven and otherwise, but

01:46:01.109 --> 01:46:04.779
what Emily highlights is um during this interlude,

01:46:04.789 --> 01:46:09.020
this three year period before the legislative framework

01:46:09.029 --> 01:46:12.699
and ERCOT market framework begins to bear fruit. Um

01:46:12.708 --> 01:46:16.600
how we sort of bridge through this operating conservatively

01:46:17.548 --> 01:46:22.159
Um How do the windows look for their purposes and granted

01:46:22.359 --> 01:46:25.208
that, as you say, the end of the spectrum bulldozing

01:46:25.220 --> 01:46:29.418
their, their lines aside, do you believe this, this

01:46:29.430 --> 01:46:32.418
becomes more of an acute challenge over time as we

01:46:32.430 --> 01:46:35.319
get into, not just going into this upcoming winter

01:46:35.329 --> 01:46:38.020
but next spring, as demand increases for that summer

01:46:41.319 --> 01:46:43.250
I mean, I, I guess it will become more of a challenge

01:46:43.259 --> 01:46:46.449
for you. I guess what we've seen is that there is a

01:46:46.458 --> 01:46:50.729
um generation can be built a lot faster than transmission

01:46:50.739 --> 01:46:53.779
in general. And so what you have have a lot of times

01:46:53.789 --> 01:46:57.449
is that you'll have uh and we talk about this, I think

01:46:57.458 --> 01:47:00.759
a lot that, that it takes you're gonna have some transmission

01:47:00.770 --> 01:47:03.149
congestion when you got a lot of new generation built

01:47:03.159 --> 01:47:06.970
remote from uh load centers and it all gets built in

01:47:06.979 --> 01:47:10.259
kind of the same area. It takes longer to get the transmission

01:47:10.270 --> 01:47:12.463
upgrade. But the thing we don't talk about as much

01:47:12.475 --> 01:47:15.713
as the outages that need to happen. The outages actually

01:47:15.725 --> 01:47:19.595
reduce the amount of capacity there is sometimes while

01:47:19.604 --> 01:47:23.244
the while the new constructions, so you have to endure

01:47:23.253 --> 01:47:25.333
a little pain before you get to the benefit in the

01:47:25.345 --> 01:47:27.958
end. And so there is, there is that issue, I'm not

01:47:27.970 --> 01:47:29.939
sure I answered your question. No, I mean, it helps

01:47:29.949 --> 01:47:33.338
frame it. I think this is, this is going to come up

01:47:33.350 --> 01:47:37.569
more next spring as well as we head into that summer

01:47:37.579 --> 01:47:39.949
with a new load growth pattern that you'll be kind

01:47:39.958 --> 01:47:43.395
of figuring into your analysis. And spring is a time

01:47:43.404 --> 01:47:45.395
when we would love to be able to take more outages

01:47:45.404 --> 01:47:47.345
and do more of this work. But we have a lot of

01:47:47.354 --> 01:47:50.083
environmental constraints on that end. And so that's

01:47:50.095 --> 01:47:53.333
another compressing factor in our schedules and, and

01:47:53.345 --> 01:47:56.314
to touch on the idea of the, the bulldozing, I can't

01:47:56.324 --> 01:47:58.708
get that image out of my head. Um That, that's not

01:47:58.720 --> 01:48:01.789
a construction method that we utilize. Uh In fact,

01:48:01.798 --> 01:48:05.588
T SPS that um are more cost aware, are gonna look at

01:48:05.600 --> 01:48:08.409
opportunities when you're doing a significant rebuild

01:48:08.430 --> 01:48:11.640
uh of an existing line to take out larger sections

01:48:11.649 --> 01:48:14.668
because it's more cost effective to do so. Um And that

01:48:14.680 --> 01:48:18.048
does in fact increase the restoration time. And the

01:48:18.060 --> 01:48:22.409
E RT uh factor that Dan was referring to uh the alternative

01:48:22.418 --> 01:48:25.149
of course, is to do more of that work energized. And

01:48:25.159 --> 01:48:27.449
there are times when we're looking to do that and having

01:48:27.458 --> 01:48:30.918
to do that. And we're talking about significant spans

01:48:30.930 --> 01:48:33.338
of line that we're rebuilding and upgrading and making

01:48:33.350 --> 01:48:36.119
more resilient through the Texas Hill country primarily

01:48:36.458 --> 01:48:39.489
And uh where we don't necessarily have the flexibility

01:48:39.500 --> 01:48:42.659
to uh increase our footprint to be able to do energized

01:48:42.668 --> 01:48:46.083
construction uh in some instances, but, but looking

01:48:46.095 --> 01:48:48.293
at it in others, so it's a constant balancing of all

01:48:48.305 --> 01:48:51.265
of these factors. And it's something that again, the

01:48:51.274 --> 01:48:53.824
more that we understand what ERCOT is looking at and

01:48:53.833 --> 01:48:56.444
their inputs and assumptions, we'll mirror that on

01:48:56.454 --> 01:48:59.125
our side and submit to them outages that conform to

01:48:59.134 --> 01:49:01.904
what they're looking for. We're looking for that efficiency

01:49:03.739 --> 01:49:07.319
and building new lines while the other circuit is hot

01:49:07.329 --> 01:49:10.680
is a safety issue and it's also expensive because there's

01:49:10.689 --> 01:49:12.739
very limited vendors out there that can do it. And

01:49:12.750 --> 01:49:15.119
I know that because I went to South Texas and saw um

01:49:15.128 --> 01:49:18.079
some construction happening and it was very educational

01:49:18.088 --> 01:49:20.770
to, to see that process happening and learning more

01:49:20.779 --> 01:49:23.759
about it. Um Our state is growing so fast, we need

01:49:23.770 --> 01:49:27.399
additional transmission power around, but at the same

01:49:27.409 --> 01:49:31.329
time, it's, it's complex given the growth and, and

01:49:31.619 --> 01:49:33.989
you know, the fact that taking out transmission can

01:49:34.000 --> 01:49:37.430
sometimes, you know, cause a reliability issue, potentially

01:49:37.439 --> 01:49:40.759
not moving around power. So it's, it's complex. But

01:49:40.770 --> 01:49:43.289
I appreciate you highlighting all the factors that

01:49:43.298 --> 01:49:46.689
you're having to take into consideration with your

01:49:46.699 --> 01:49:49.390
um build out and interconnection and all the different

01:49:49.399 --> 01:49:51.869
challenges on your system. I think I'm sure you're

01:49:51.878 --> 01:49:55.119
not alone. Um But it's helpful to hear that insight

01:49:55.128 --> 01:49:57.789
because I think as Commissioner McAdams noted something

01:49:57.798 --> 01:50:00.430
we got to keep on our radar and see if there's ways

01:50:00.439 --> 01:50:04.180
to make improvements or changes or, you know, as you

01:50:04.189 --> 01:50:06.458
noted some kind of collaboration between all of us

01:50:06.470 --> 01:50:08.989
to, to look at the issue. Thank you. Thank you.

01:50:11.759 --> 01:50:15.798
Questions. No. Ok. Thank you. Thank you, Emily. Thank

01:50:15.810 --> 01:50:19.039
you. Thank you, Dan. And next we have All Park Courtney

01:50:29.088 --> 01:50:31.430
Good morning. Um For the record of Courtney Altman

01:50:31.439 --> 01:50:34.539
chief Executive and Public Councils for the Office

01:50:34.548 --> 01:50:37.560
of Public Utility Council. I appreciate the commission

01:50:37.640 --> 01:50:39.668
hosting this workshop today and allowing us to give

01:50:39.680 --> 01:50:42.609
comments. Um For those of you listening who do not

01:50:42.619 --> 01:50:45.128
know OPEC is a separate state agency actually from

01:50:45.140 --> 01:50:48.989
PUC and we are specifically um advocating for residential

01:50:49.000 --> 01:50:53.259
and small commercial consumers in Texas. Um We at OPEC

01:50:53.378 --> 01:50:56.520
take this role of making sure that consumers have a

01:50:56.529 --> 01:50:59.699
voice in any issues before the PUC C and ERCOT very

01:50:59.708 --> 01:51:03.359
seriously. And that is because we know that it is ultimately

01:51:03.369 --> 01:51:06.949
the consumer who ends up paying for many of these projects

01:51:07.189 --> 01:51:10.649
that weatherization, emergency pricing or additional

01:51:10.659 --> 01:51:14.418
reliability measures. Having said that OPEC is also

01:51:14.430 --> 01:51:17.168
very concerned and supports the commission and ERCOT

01:51:17.208 --> 01:51:20.579
in its efforts to ensure a reliable grid for Texans

01:51:20.588 --> 01:51:23.548
not just for the winner, but for always, you and the

01:51:23.560 --> 01:51:25.649
commission are aware but for those not some of the

01:51:25.659 --> 01:51:29.298
ways OPEC advocates for consumers is by intervening

01:51:29.310 --> 01:51:32.279
in rate cases that are filed in an effort to help keep

01:51:32.289 --> 01:51:35.628
prices down. We offer comments to PUC C when adopting

01:51:35.640 --> 01:51:39.319
rules or changing standards to again address how such

01:51:39.329 --> 01:51:42.640
changes might hinder a consumer. And then we finally

01:51:42.649 --> 01:51:45.458
have a seat at ERCOT on the board where we have a

01:51:45.470 --> 01:51:48.909
vote and represent consumers. Now, um we are not just

01:51:48.918 --> 01:51:52.140
always um filing comments, we also um have the role

01:51:52.149 --> 01:51:55.140
of educating consumers and connecting them to various

01:51:55.149 --> 01:51:59.430
programs. We at OPEC operate a helpline via phone and

01:51:59.439 --> 01:52:02.850
email. We often are answering questions and helping

01:52:02.859 --> 01:52:06.609
consumers navigate certain issues. We will be educating

01:52:06.619 --> 01:52:10.378
them, helping them um know their consumer rights. What

01:52:10.390 --> 01:52:13.319
questions to ask when they're speaking to the utility

01:52:13.359 --> 01:52:16.009
we will um point them to the power to, to choose web

01:52:16.134 --> 01:52:19.444
site that the PUC hosts and again, tell them the questions

01:52:19.454 --> 01:52:21.774
that they might need to ask before making that change

01:52:22.055 --> 01:52:25.225
And often there are disconnection issues and or trouble

01:52:25.234 --> 01:52:28.375
paying the utility bill and we will point them to resources

01:52:28.384 --> 01:52:31.213
that we know are available. Um Those will be either

01:52:31.225 --> 01:52:34.543
at the state level, at agencies sometimes um at the

01:52:34.555 --> 01:52:38.194
local level within their own um county or city and

01:52:38.204 --> 01:52:40.194
sometimes there are charities that have resources.

01:52:40.204 --> 01:52:42.914
So depending on where that consumer is located, we

01:52:42.923 --> 01:52:46.409
will point them in the right direction. Um Not to take

01:52:46.418 --> 01:52:49.609
too much time, but I do want the commission to know

01:52:49.619 --> 01:52:53.449
as it considers going forward or sending directives

01:52:53.458 --> 01:52:57.628
to ERCOT be that for winterization or other related

01:52:57.640 --> 01:53:00.750
items. Um We at OPEC plan to continue to represent

01:53:00.759 --> 01:53:04.168
consumer interests and advocate for reliable energy

01:53:04.180 --> 01:53:07.699
but with fair cost to the consumers. And we ask that

01:53:07.708 --> 01:53:10.779
you also keep that in mind as you move forward. Um

01:53:10.789 --> 01:53:12.798
Thank you, look forward to working with you. Our office

01:53:12.810 --> 01:53:14.918
looks forward to working with you, staff and other

01:53:14.930 --> 01:53:17.319
stakeholders. Happy to answer questions.

01:53:19.500 --> 01:53:21.949
Courtney, appreciate you being here today and I did

01:53:21.958 --> 01:53:24.199
have one question for you. So you know, one of the

01:53:24.208 --> 01:53:27.048
things I think that's been made available to Texas

01:53:27.060 --> 01:53:30.270
consumers in the past, recognizing that in the winter

01:53:30.279 --> 01:53:33.609
you know, your, your usage is up and possibly your

01:53:33.619 --> 01:53:37.119
bill is up. So, um T DH ca I guess in the

01:53:37.128 --> 01:53:39.208
past has had some funding. Do you have any insight

01:53:39.220 --> 01:53:42.079
on that for us? Yes. Um We have checked a and they

01:53:42.088 --> 01:53:45.289
do have funding usually sometimes um right now they

01:53:45.298 --> 01:53:48.689
for the electricity bills that has been depleted. Um

01:53:48.699 --> 01:53:53.409
They have a little left for water usage, um but it's

01:53:53.418 --> 01:53:53.930
very,

01:53:55.470 --> 01:53:58.729
very small and they will probably be closing that window

01:53:58.739 --> 01:54:00.909
pretty quickly because the amount has gotten down.

01:54:00.918 --> 01:54:03.878
But I do expect it will be hopefully replenished soon

01:54:03.979 --> 01:54:08.020
So it is something that we will point consumers towards

01:54:08.029 --> 01:54:11.009
if we know it's filled back up and therefore for consumers

01:54:11.430 --> 01:54:14.259
Is that subject to federal replenishment? Yes.

01:54:16.759 --> 01:54:20.899
Ok. Thank you. Thank you. Thank you. Thank you, Courtney

01:54:21.430 --> 01:54:24.739
Now we are changing subjects. Next will be monthly

01:54:24.750 --> 01:54:28.470
outlook for resource adequacy, also known as Mora and

01:54:28.720 --> 01:54:29.739
RCAT staff Pete.

01:54:38.079 --> 01:54:38.649
Some of them.

01:54:41.600 --> 01:54:44.100
Good morning commissioners. I'm uh Pete Warnken. I

01:54:44.109 --> 01:54:47.819
manage the resource adequacy department at Ricco. And

01:54:47.829 --> 01:54:52.378
what I wanted to do today is uh review the plant resources

01:54:52.390 --> 01:54:56.020
that we expect for the winter and then, uh do a quick

01:54:56.029 --> 01:55:00.100
recap of our December M report and then do a sneak

01:55:00.109 --> 01:55:02.878
peek of uh what we're gonna see for the January more

01:55:03.289 --> 01:55:05.180
and I want to qualify everything. I'm gonna say that

01:55:05.189 --> 01:55:09.640
this is all preliminary. So, um so this slide is showing

01:55:10.029 --> 01:55:13.609
uh for start of December. And again, this is uh based

01:55:13.619 --> 01:55:18.128
on the Mora report, um what the resources are that

01:55:18.140 --> 01:55:22.220
we expect. And again, you'll see, uh again, it's solar

01:55:22.628 --> 01:55:26.829
um and, and wind and then for the start of January

01:55:26.838 --> 01:55:30.729
uh we have a lot of resources that uh that come in

01:55:30.949 --> 01:55:33.149
uh into operation towards the end of the year. I think

01:55:33.159 --> 01:55:36.548
a lot of that's driven by, um you know, tax incentives

01:55:36.560 --> 01:55:40.939
and, and schedules. So, uh we have one resource coming

01:55:40.949 --> 01:55:45.869
in. Uh it's a 60 Megawatt uh natural gas unit. Uh The

01:55:45.878 --> 01:55:49.390
bulk of it is uh is solar and energy storage and wind

01:55:49.619 --> 01:55:52.509
and obviously the solar doesn't help us out too much

01:55:52.520 --> 01:55:56.109
in the winter time. Um But, and, and wind does a little

01:55:56.119 --> 01:56:00.369
bit uh wind actually ramps up in January, I mean, relative

01:56:00.378 --> 01:56:04.350
to December. So it, it, it is helpful. Um And then

01:56:05.208 --> 01:56:10.810
uh so these numbers you'll see in the, the January

01:56:10.819 --> 01:56:13.128
M report for that, that start of January.

01:56:15.489 --> 01:56:20.859
Ok. Next slide, please. So again, a recap of the December

01:56:20.869 --> 01:56:24.810
Mora. Again, this is under normal conditions and you'll

01:56:24.819 --> 01:56:28.239
see we've got the total load forecast up at the top

01:56:28.729 --> 01:56:31.298
and you know, way at the bottom we have our measure

01:56:31.310 --> 01:56:34.859
of risk capacity available for operating reserves and

01:56:34.869 --> 01:56:37.850
under normal conditions. Uh we should be in very good

01:56:37.859 --> 01:56:40.789
shape and of course, this is just a part of the story

01:56:41.250 --> 01:56:44.239
Um Again, the more it deals with the risk assessment

01:56:44.250 --> 01:56:47.009
Um So, uh with that, I want to go to the next

01:56:47.020 --> 01:56:48.000
slide real quickly.

01:56:51.539 --> 01:56:54.699
So again, the whole basis or most of the basis of the

01:56:54.708 --> 01:56:58.000
Moore Report uh is to show the likelihood that we're

01:56:58.009 --> 01:57:01.619
going to get into an ee a situation or possibly uh

01:57:01.628 --> 01:57:06.430
you know, ro rotating outages. Um And again, the more

01:57:06.489 --> 01:57:09.989
looks by hour to hour and you'll see that the highest

01:57:10.000 --> 01:57:12.439
risk period of time is in the morning. Uh Again, I'm

01:57:12.449 --> 01:57:15.659
talking about December here, so you'll see it's starting

01:57:15.668 --> 01:57:19.180
to ramp up uh the risk at 7 a.m. and then it

01:57:19.189 --> 01:57:22.079
it culminates in the peak at 8 a.m. So we have a

01:57:22.088 --> 01:57:26.329
uh a little over 5% risk of an E A being declared

01:57:27.100 --> 01:57:31.378
And then similarly for rotating outages, the probability

01:57:31.390 --> 01:57:37.229
is just over 4%. Um and then the risk goes down and

01:57:37.239 --> 01:57:39.458
then it goes back up a little bit uh in the early

01:57:39.470 --> 01:57:42.079
evening when you have your, uh, you know, your solar

01:57:42.088 --> 01:57:45.409
you know, ramping down and then loads pick up towards

01:57:45.418 --> 01:57:49.298
the end of the day. And then on the right hand side

01:57:49.409 --> 01:57:53.649
again, this is the same type of run that we did for

01:57:53.659 --> 01:57:57.729
the base, except that we fixed the load forecast based

01:57:57.739 --> 01:58:02.619
on, uh, winter storm Elliott weather. And also we fixed

01:58:02.628 --> 01:58:06.588
the, uh, uh, the outages as well. Um This is the weather

01:58:06.720 --> 01:58:09.770
related outages. So you'll see here that there is a

01:58:09.779 --> 01:58:14.310
big risk uh, at 8 a.m. if you have a winter storm

01:58:14.319 --> 01:58:16.958
that, that impacts the system at that time of the day

01:58:18.520 --> 01:58:22.418
Um And so now jumping ahead to the, the February or

01:58:22.430 --> 01:58:25.750
excuse me, the January release of the Mora. So what

01:58:25.759 --> 01:58:28.239
you're gonna see is you're gonna see, uh, you know

01:58:28.250 --> 01:58:31.899
more risk than you did in January. And the big reason

01:58:31.909 --> 01:58:35.458
why is because, uh, there's higher, uh, you know, loads

01:58:35.470 --> 01:58:39.899
during January, uh on the order of about 5000 megawatts

01:58:40.720 --> 01:58:44.048
Uh Now offsetting that a little bit is, uh, is planned

01:58:44.060 --> 01:58:47.079
outages. Usually those go down in January relative

01:58:47.088 --> 01:58:50.609
to uh December. And as I mentioned before, the, you

01:58:50.619 --> 01:58:54.088
know, the wind picks up in January relative to December

01:58:54.100 --> 01:58:57.069
So you do see a couple of offsets to that, that high

01:58:57.079 --> 01:58:59.949
load, but that's gonna be a big driver. So you're gonna

01:58:59.958 --> 01:59:02.810
see, you know, higher numbers here, higher, uh you

01:59:02.819 --> 01:59:05.958
know probabilities in the January Report. Than you

01:59:05.970 --> 01:59:10.458
did in December. So that's all I wanted to present

01:59:11.628 --> 01:59:15.628
any questions. Yeah, Pete. Um, I think I heard you

01:59:15.640 --> 01:59:18.810
say that the slide with the additional resources coming

01:59:18.819 --> 01:59:21.970
online are those are expected to come on in January

01:59:22.949 --> 01:59:24.208
the bar chart, I guess.

01:59:25.909 --> 01:59:30.668
Yeah. So, so the start of December is, uh, you know

01:59:30.680 --> 01:59:34.779
what we expect, you know, for the, for the January

01:59:34.789 --> 01:59:40.279
report and then for the start of, for January or, excuse

01:59:40.289 --> 01:59:43.850
me, I take that back, start of December is the, you

01:59:43.859 --> 01:59:46.918
know, the December Mora and then the start of January

01:59:47.029 --> 01:59:50.770
is what we're going to see in the January Mora report

01:59:50.779 --> 01:59:54.869
that's coming out in a few weeks. Ok. All right. Yes

01:59:54.878 --> 01:59:56.458
Thank you for breaking that down. It, it's a little

01:59:56.470 --> 02:00:01.600
early for me still this morning. Um, but, um, ok, so

02:00:02.319 --> 02:00:06.329
in the December Mora you factored in, I guess this

02:00:06.338 --> 02:00:11.270
the additional resources there, the 326 320 to whatever

02:00:11.279 --> 02:00:13.418
degree that you were factor them in based on their

02:00:13.430 --> 02:00:17.208
capability during the winter and then the January,

02:00:17.220 --> 02:00:21.009
um, resources, those aren't, were those factored into

02:00:21.020 --> 02:00:25.628
the December Maura? For, I mean, I guess factored in

02:00:25.640 --> 02:00:27.529
this is probably discussion for later today. But I

02:00:27.539 --> 02:00:31.079
guess my question would be when Norcott looked at the

02:00:31.088 --> 02:00:34.949
MOA identified the risk and saw there's a capacity

02:00:34.958 --> 02:00:38.220
need. Did, did you factor in the resources coming in

02:00:38.229 --> 02:00:41.680
in January? So if you're talking about what we did

02:00:41.689 --> 02:00:45.548
for the capacity RFP analysis. Yes, that, that was

02:00:45.560 --> 02:00:49.970
a season wide review. So again, this is just focused

02:00:49.979 --> 02:00:51.520
on each month at a time.

02:00:54.649 --> 02:00:57.128
So the, the January results that you'll see in the

02:00:57.140 --> 02:01:00.708
Morrow report will be, you know, fairly similar to

02:01:00.720 --> 02:01:03.628
to what you see, uh that what we did for the uh

02:01:03.640 --> 02:01:08.829
the seasonal view for the, the, the capacity RP. OK

02:01:08.838 --> 02:01:11.250
And, and I'll reserve that discussion for later this

02:01:11.259 --> 02:01:13.079
afternoon because I know everybody's interested in

02:01:13.088 --> 02:01:16.109
it and I don't wanna dig too deep in there, but with

02:01:16.119 --> 02:01:18.659
respect to the probabilistic analysis for the December

02:01:18.668 --> 02:01:22.588
Mora, um you highlighted an extreme scenario, Winter

02:01:22.600 --> 02:01:27.579
Scorm Elliott and, and so to come up with the more

02:01:27.588 --> 02:01:31.229
in general ERCOT conducted um probabilistic analysis

02:01:31.239 --> 02:01:33.779
that included thousands of scenarios that they ran

02:01:33.789 --> 02:01:38.439
with Monte Carlo simulation out of that pie. What is

02:01:38.449 --> 02:01:40.609
the probability that we'll get a winner to? Million

02:01:43.649 --> 02:01:45.659
Yeah, I'm probably not the best person to answer that

02:01:45.668 --> 02:01:50.479
I, I think probably 10 to, to 20% chance. Um I don't

02:01:50.489 --> 02:01:54.970
know if uh maybe Woody, I think you, you had any thoughts

02:01:54.979 --> 02:01:55.659
about that?

02:02:00.009 --> 02:02:03.798
Uh Woody Rickerson with ERCOT. So it was 1/90 percentile

02:02:03.810 --> 02:02:08.069
storm that equates to roughly one in 10 years. Ok.

02:02:13.489 --> 02:02:15.560
Ok. I'm just, ok. Thank you. I'm just trying to get

02:02:15.569 --> 02:02:18.189
a sense right? Of just kind of unpacking some of the

02:02:18.199 --> 02:02:20.829
probabilistic analysis and, and obviously wanna make

02:02:20.838 --> 02:02:22.850
sure we're ready for extreme weather. Scenarios and

02:02:22.859 --> 02:02:26.060
just trying to understand how often we would expect

02:02:26.069 --> 02:02:27.859
to see a storm like this. Of course, sometimes you

02:02:27.869 --> 02:02:31.109
get storms that you weren't expecting. Um But it's

02:02:31.119 --> 02:02:33.668
helpful to understand just to put it in context in

02:02:33.680 --> 02:02:36.140
further context. So is that

02:02:37.859 --> 02:02:40.140
it's a 5% chance Elliot, he then

02:02:42.979 --> 02:02:45.199
the one in 10. Ok. Um

02:02:47.390 --> 02:02:48.119
Yeah. Ok.

02:02:49.699 --> 02:02:54.548
Based on historic, so one observation over two months

02:02:54.560 --> 02:02:58.819
we have 3000 megawatts of capacity of some type coming

02:02:58.829 --> 02:03:02.208
into the system which on its face, that's an impressive

02:03:02.220 --> 02:03:08.100
number. Woody from your operational perspective. 943

02:03:08.109 --> 02:03:14.838
of that. Yep. Well, and over 1000 1200 megawatts round

02:03:14.850 --> 02:03:18.229
about are going to be dispatchable in terms of energy

02:03:18.239 --> 02:03:20.739
storage, energy storage. All right, let's let's drill

02:03:20.750 --> 02:03:23.338
down on that. Yeah. When I look at that bar chart,

02:03:23.350 --> 02:03:27.449
I see solar, the 1065 megawatts won't be any use at

02:03:27.458 --> 02:03:29.789
all. I'm talking about 8 a.m. I'm thinking about 8

02:03:29.798 --> 02:03:34.128
a.m. like you are, is that one hour solar at 8 a.m.

02:03:34.140 --> 02:03:42.579
or at six? I understand the wind has ac 18. Is that

02:03:42.720 --> 02:03:45.958
right? Yeah, it's higher higher in the winter than

02:03:45.970 --> 02:03:49.180
summer. You can shrink those, those two parts of the

02:03:49.259 --> 02:03:56.739
Gulf energy storage will be, can be very valuable for

02:03:56.750 --> 02:03:58.600
that three or four hour period in the morning and the

02:03:58.609 --> 02:04:01.548
evening, depending on how it's dispatched. Right? I

02:04:01.569 --> 02:04:05.229
mean that that is the bridge to the future right now

02:04:06.119 --> 02:04:09.600
So is it your belief? And I'll hand over to Commissioner

02:04:10.079 --> 02:04:12.789
Glotfelty that, that is on the whole onehour batteries

02:04:12.930 --> 02:04:17.109
that we're seeing as a base case. So the way that's

02:04:17.119 --> 02:04:21.829
listed there, that's roughly equivalent to the energy

02:04:21.838 --> 02:04:25.149
stored also. So yes, it would be equivalent to a one

02:04:25.159 --> 02:04:26.789
hour. Now, some of those may actually be more than

02:04:26.798 --> 02:04:30.199
one hour batteries. But the way we classify this, we

02:04:30.208 --> 02:04:34.878
classify it by their inverter size. So there may be

02:04:34.890 --> 02:04:39.279
a few more Megawatt hours hidden behind that, whatever

02:04:39.289 --> 02:04:43.878
that number is. Um, 9 43 there may be a few more

02:04:43.890 --> 02:04:47.069
Megawatt hours of energy there, but we'll never be

02:04:47.079 --> 02:04:51.520
able to get more than 943 megawatts out for a given

02:04:51.529 --> 02:04:56.119
hour. That makes sense. Yeah, there may be some two

02:04:56.229 --> 02:04:58.619
hour batteries and mixed in there with the one hour

02:04:58.779 --> 02:05:02.579
ones. I have a question on the EL C comment that you

02:05:02.588 --> 02:05:08.619
made. So you said wind is 19 or 18% of whatever LC

02:05:08.628 --> 02:05:12.289
it doesn't matter what the number is, but that's pegging

02:05:12.298 --> 02:05:19.829
that resource to one hour, right? So 19% of that uh

02:05:19.838 --> 02:05:23.199
of that 30,000 megawatts is actually going for resource

02:05:23.208 --> 02:05:23.750
adequacy.

02:05:25.560 --> 02:05:30.020
Yeah, the way, the way I think of ELC is, if the

02:05:30.029 --> 02:05:37.048
ELC of wind is, is 18% then for our calculations, 18

02:05:37.060 --> 02:05:40.000
megawatts of dispatchable generation would be equivalent

02:05:40.009 --> 02:05:44.399
to 100 megawatts of wind generation as far as its ability

02:05:44.409 --> 02:05:48.489
to support load, 18 megawatts of dispatchable is equivalent

02:05:48.500 --> 02:05:53.729
to 100 megawatts of wind. Right. But my question is

02:05:53.979 --> 02:05:58.699
really, it gets to thermal outages. I mean, that EL

02:05:58.890 --> 02:06:03.850
C number actually does, doesn't it theoretically change

02:06:03.939 --> 02:06:07.338
the more force outages that you have the higher EL

02:06:07.489 --> 02:06:11.270
C because the more you need that resource to satisfy

02:06:11.279 --> 02:06:13.699
load because there's less coming out of the thermal

02:06:14.029 --> 02:06:20.539
fleet. Now, the way the ELC works is, um this is, it's

02:06:20.548 --> 02:06:23.310
lucky I got Pete sitting here beside me. So mail me

02:06:23.319 --> 02:06:28.208
out here, I dive into the ELC. So you, you, you, you

02:06:28.220 --> 02:06:30.899
set your reliability standard, you say, OK, my reliability

02:06:30.909 --> 02:06:37.449
standard is, is X and then you take all the wind out

02:06:38.359 --> 02:06:41.600
and then you start incrementally adding back in dispatchable

02:06:41.609 --> 02:06:44.699
generation until you get to the same reliability standard

02:06:45.569 --> 02:06:49.109
That's how the reliability standard is, is the ELC

02:06:49.119 --> 02:06:53.000
is, is calculated. Now, when you say forced outages

02:06:53.009 --> 02:06:55.430
are you talking about forced outages of thermal, wind

02:06:55.439 --> 02:06:58.579
or thermals, thermal, thermal? I mean, yeah, I mean

02:06:58.640 --> 02:07:03.500
and this December peak load day, you have 12% of the

02:07:03.509 --> 02:07:07.149
thermal fleet is on forced outage. So it's the EL C

02:07:07.159 --> 02:07:11.939
number is independent looking at, I know it is. Well

02:07:11.989 --> 02:07:16.949
I go on well, so again, the EL C is, is an

02:07:16.958 --> 02:07:21.128
annual number, the way you calculated it. So that will

02:07:21.140 --> 02:07:24.009
go into for example, the capacity demand and reserves

02:07:24.020 --> 02:07:28.729
report. So for the more reports, what we do is we look

02:07:28.739 --> 02:07:33.810
at profiles, generation, profiles, historical and compile

02:07:33.819 --> 02:07:37.180
probability distribution for each individual hour.

02:07:38.069 --> 02:07:41.180
So it's different than, than the LC. But you know,

02:07:41.189 --> 02:07:45.449
Woody, Woody's right. If you have, you know, outages

02:07:45.899 --> 02:07:50.588
thermal outages, that will raise CC because that's

02:07:50.600 --> 02:07:55.009
dependent both on the outages as well as other resources

02:07:55.020 --> 02:07:58.239
as well. So if I heard, I think you confirmed what

02:07:58.250 --> 02:08:00.159
I was saying, which is if you have a higher forced

02:08:00.168 --> 02:08:04.810
outage rate, the ELC of those resources will go up

02:08:04.958 --> 02:08:13.039
That's correct. So, um I know the mostly it's reverse

02:08:13.069 --> 02:08:17.289
your expected load carrying capacity for that resource

02:08:17.298 --> 02:08:20.279
declines because it should be reflected in the historical

02:08:20.289 --> 02:08:25.509
LC of that resource. I think we're mixing up. So the

02:08:25.520 --> 02:08:27.989
EL C of a thermal unit would go down if it has

02:08:28.000 --> 02:08:31.378
more forced, I'm sorry, I'm talking about the higher

02:08:31.390 --> 02:08:35.000
forced outage rate of the thermal fleet should raise

02:08:35.009 --> 02:08:39.270
the EL C of the non, right. That's what I was correct

02:08:40.270 --> 02:08:46.060
So, what I see in here is we, we're taking a snapshot

02:08:46.069 --> 02:08:48.418
and I know, you know, you've done a lot of uh of

02:08:48.430 --> 02:08:51.759
these model runs, but this is just one day at one hour

02:08:51.770 --> 02:08:56.128
with one certain set of assumptions with 12% of the

02:08:56.449 --> 02:08:58.680
fleet out. Um

02:09:00.199 --> 02:09:05.439
This seems pretty dire at 8 a.m. But I, I also see

02:09:05.449 --> 02:09:07.850
what Commissioner mcadam said, which is, you know,

02:09:07.859 --> 02:09:12.109
if, if on this slide, we have 1200 megawatts of storage

02:09:12.759 --> 02:09:17.899
and in this chart, we only have uh 1200 megawatts of

02:09:17.909 --> 02:09:23.708
storage. Um So 1200 new megawatts in January, December

02:09:23.720 --> 02:09:28.479
and January. But in, in this chart, we only have in

02:09:28.750 --> 02:09:32.899
this chart on the other slide. Yeah. There we go. No

02:09:32.909 --> 02:09:37.548
go back there. It, it says 1229 megawatts of storage

02:09:37.560 --> 02:09:41.100
for that hour. Do th how come those numbers don't add

02:09:41.109 --> 02:09:44.500
I don't understand that. Well, we've done a recent

02:09:44.509 --> 02:09:48.069
analysis looking at the state of charge on an hourly

02:09:48.079 --> 02:09:54.079
basis for batter. So yeah, so the number that we're

02:09:54.088 --> 02:09:56.829
going to be putting into the next Moore report is going

02:09:56.838 --> 02:10:00.168
to be higher than that. So again, we've looked at what

02:10:00.180 --> 02:10:03.548
we expect in January and it's certainly going to be

02:10:03.560 --> 02:10:07.180
much higher than that number. So it will improve. But

02:10:07.189 --> 02:10:10.779
is the 3000 Megawatt discussion that we're going to

02:10:10.789 --> 02:10:13.699
have this afternoon based upon this number or is it

02:10:13.708 --> 02:10:17.750
based upon a new Mora number? Well, it's again, it's

02:10:17.759 --> 02:10:23.798
based upon um a new more number. So yeah, you'll see

02:10:23.810 --> 02:10:26.989
that kind of upwards of, you know, 2 to 3000 megawatts

02:10:27.000 --> 02:10:30.509
of battery availability. So that's what we used in

02:10:30.520 --> 02:10:34.009
the, in the in that capacity study. Ok, that's that

02:10:34.020 --> 02:10:37.509
But how many, so what is the capacity of storage on

02:10:37.520 --> 02:10:40.529
our system today in terms of megawatts, it's about

02:10:40.539 --> 02:10:45.409
4000 megawatts and we're still not accounting for all

02:10:45.418 --> 02:10:48.350
of that. Is that because some of it's being pulled

02:10:48.359 --> 02:10:50.810
out for ancillary services. I think the most we even

02:10:50.819 --> 02:10:55.109
during the scarcest hours, remember you hours don't

02:10:55.119 --> 02:10:57.369
live in a vacuum. They've got hours in front of them

02:10:57.378 --> 02:10:59.720
and hours behind them and all those hours are pulling

02:10:59.729 --> 02:11:04.359
energy. So I think the most we saw during some of these

02:11:04.369 --> 02:11:09.949
tight times was about 1700. Ok. It's kind of the learning

02:11:09.958 --> 02:11:13.229
curve. And so, yeah, so if you look at that, you can

02:11:13.239 --> 02:11:16.989
say, well, that's less than less than half the capacity

02:11:17.000 --> 02:11:19.609
or half of the Megawatt hours were ever used in one

02:11:19.619 --> 02:11:23.930
single hour. And, and also keep in mind that it varies

02:11:23.958 --> 02:11:25.119
within the hour.

02:11:26.869 --> 02:11:31.270
So it may peak at a number at 6 30 it may

02:11:31.279 --> 02:11:35.739
be something less than that 6 45. So, I mean, there's

02:11:36.329 --> 02:11:39.029
we think in hours, but it's actually moving around

02:11:39.039 --> 02:11:43.708
within the hour as well. Ok. So even though we're adding

02:11:43.720 --> 02:11:46.548
1200 megawatts, you're not gonna get 1200 megawatts

02:11:46.560 --> 02:11:50.899
in any given hour of new dispatchable generation available

02:11:50.909 --> 02:11:53.509
to put on the grid for that hour. It's gonna be some

02:11:53.939 --> 02:11:59.079
percentage. OK? I have another question regarding the

02:11:59.418 --> 02:12:04.208
pistic analysis that was done. So the two charts, the

02:12:04.220 --> 02:12:07.600
the one with the I guess normal conditions and one

02:12:07.609 --> 02:12:11.720
with Elliot factored in, you have a um does, does that

02:12:11.729 --> 02:12:15.449
first chart include any extreme weather like Elliott

02:12:16.100 --> 02:12:18.838
I mean, this chart assumes it's gonna happen the second

02:12:18.850 --> 02:12:23.009
one, but does the first one include extreme weather

02:12:23.020 --> 02:12:27.779
I mean. Yes. Ok. Ok. So, so how do you then differentiate

02:12:27.789 --> 02:12:30.390
I guess one assumes you're having Elliott, but the

02:12:30.399 --> 02:12:33.298
first one assumes you're having extreme weather. What's

02:12:33.310 --> 02:12:35.529
the difference? Is there an additional waiting or assumption

02:12:35.539 --> 02:12:39.009
that? Well, that's right. There's the probability of

02:12:39.020 --> 02:12:43.739
you know, outages and, and load high loads. So the

02:12:43.750 --> 02:12:47.649
probability is, is, is much lower. Uh, you know, when

02:12:47.659 --> 02:12:49.958
you're looking on that, that, that left side analysis

02:12:49.970 --> 02:12:52.659
on the right side, you're actually fixing the load

02:12:52.918 --> 02:12:56.859
and the outages. So you're basically saying a winter

02:12:56.869 --> 02:12:59.930
storm will occur. Whereas the one on the left there

02:12:59.939 --> 02:13:02.739
is ok, there, there's a probability but it's small

02:13:03.020 --> 02:13:05.548
but you're, you're actually including that in the overall

02:13:05.560 --> 02:13:08.229
results. What's that probability is that the 10% that

02:13:08.239 --> 02:13:11.539
Woody just mentioned or just be careful with that 10%

02:13:13.199 --> 02:13:15.859
put in context, I'll be careful. I was trying to understand

02:13:15.949 --> 02:13:16.668
it Woody.

02:13:19.649 --> 02:13:22.390
I do know though if you think if you just look back

02:13:22.399 --> 02:13:23.310
at the last

02:13:24.939 --> 02:13:28.079
12 years, 10 years, how many Elliott type storms have

02:13:28.088 --> 02:13:30.579
we had? There's been four or five that have been at

02:13:30.588 --> 02:13:35.159
the of that uh that magnitude that, that cold and also

02:13:35.220 --> 02:13:38.189
to set another number straight, that 1700 was over

02:13:38.199 --> 02:13:42.359
2000, then just showed me a graph. It's 2000 megawatts

02:13:42.369 --> 02:13:44.270
of battery peak

02:13:45.918 --> 02:13:48.588
during those events during, during any, at one event

02:13:48.600 --> 02:13:53.958
at least. Um So, ok, so I'm just trying to understand

02:13:53.970 --> 02:13:57.259
this. The first chart assumes the same level of load

02:13:57.270 --> 02:14:00.359
growth, right? About five gigs. And then the second

02:14:00.369 --> 02:14:03.509
chart, the both charts include this chart, right? Yes

02:14:03.560 --> 02:14:05.649
those two charts, they, they both assume higher load

02:14:05.659 --> 02:14:10.668
growth. Well, yeah, in December. So when you see the

02:14:10.680 --> 02:14:13.899
the January report, you'll, you'll see the higher load

02:14:13.909 --> 02:14:16.680
growth. That was the 5000 megawatts I was referring

02:14:16.689 --> 02:14:21.180
to. So, relative to what we see in December, the peak

02:14:21.189 --> 02:14:24.899
load will be roughly 5000 megawatts higher than that

02:14:25.600 --> 02:14:33.100
So, ok, so Elliott was about 73,000 Megawatt peak.

02:14:33.689 --> 02:14:38.250
And so for December, you're adding five to that. Well

02:14:38.259 --> 02:14:40.810
again, that's just the normal peak load growth. If

02:14:40.819 --> 02:14:44.048
you're looking at, um, Elliott on top of that, you're

02:14:44.060 --> 02:14:49.119
you're talking about 78 to 79,000 and you know, for

02:14:49.128 --> 02:14:51.899
the load growth. So then in January, are you going

02:14:51.909 --> 02:14:54.298
to add 5000 more? So you'll be like it, I don't know

02:14:54.310 --> 02:14:59.390
84 83. Well, we'll probably be around 79,000 about

02:14:59.399 --> 02:15:04.180
the same. Yeah. Ok. So it reflects the same load growth

02:15:04.189 --> 02:15:06.869
pattern of the summer, right? So I was just trying

02:15:06.878 --> 02:15:08.930
to, ok, so you'll take the 5000 and carried it through

02:15:08.939 --> 02:15:11.310
the whole winter, right? That's what I was trying to

02:15:11.319 --> 02:15:17.220
get to. Ok. So that first chart in involved, it includes

02:15:17.229 --> 02:15:19.520
extreme weather conditions and some kind of probability

02:15:19.529 --> 02:15:22.020
that will get some kind of Elliott. But the other one

02:15:22.029 --> 02:15:27.989
assumes it happens. Um I mean it's happening. So with

02:15:28.000 --> 02:15:30.369
thermal generation outages, I mean, Commissioner Gel

02:15:30.668 --> 02:15:35.659
he mentioned, what was that number? 12% at the peak

02:15:35.668 --> 02:15:38.418
of Elliot. It was 14,000 thermal generation outages

02:15:38.430 --> 02:15:42.458
Where, where is that factored in? So what's built into

02:15:42.470 --> 02:15:46.020
the model is a, is a curve, a probability curve that

02:15:46.029 --> 02:15:49.878
relates low temperature to weather related outages

02:15:49.918 --> 02:15:53.529
So the model will select a a temperature value And

02:15:53.539 --> 02:15:56.909
again, it's based on a probability. So as temperature

02:15:56.918 --> 02:15:59.250
goes down, the chance of the model selecting that goes

02:15:59.259 --> 02:16:02.930
goes down, but if, if you select a temperature below

02:16:02.939 --> 02:16:08.369
a certain threshold, and that's basically 15 degrees

02:16:08.750 --> 02:16:13.479
And at that level, you've got Elliot type weather impacts

02:16:13.489 --> 02:16:16.560
happening. So that's what's built into the model. So

02:16:16.569 --> 02:16:19.100
the model will select at low temperature and that will

02:16:19.109 --> 02:16:21.739
trigger a certain amount of, of weather related outages

02:16:21.750 --> 02:16:25.489
that the model selects. So that's how it works. So

02:16:25.500 --> 02:16:28.119
the way I think of those two charts is um

02:16:29.819 --> 02:16:33.929
the chart on the left has all the uh all the outcomes

02:16:33.940 --> 02:16:36.690
from all the distribution runs. So some of them had

02:16:36.700 --> 02:16:38.668
Elliott weather, some of them did. And is that for

02:16:38.679 --> 02:16:42.000
42 years, the same as the weather, uh the reliability

02:16:42.009 --> 02:16:46.259
standard that we're modeling, it's 42 year backcast

02:16:46.759 --> 02:16:50.418
Yeah, we have uh the wind and solar goes back. Yeah

02:16:50.429 --> 02:16:54.530
42 years. Yeah. So the, the one on the left has all

02:16:54.540 --> 02:16:58.450
the distributions in there. And those are the probabilities

02:16:58.459 --> 02:17:01.120
that come out if you use all the, all the outcomes

02:17:01.929 --> 02:17:03.540
and if you look at the one on the right, it would

02:17:03.549 --> 02:17:07.250
be the same outcomes except you would, anything that

02:17:07.259 --> 02:17:09.959
didn't have Elliott type weather in it you would take

02:17:09.968 --> 02:17:14.468
out. And so it's a reduced set that has only the only

02:17:14.479 --> 02:17:18.599
the Elliott weather in it. And that's the distributions

02:17:18.610 --> 02:17:23.459
on the right. Have just the Elliot weather. Ok. And

02:17:23.468 --> 02:17:27.489
if you did that same thing for January, all those numbers

02:17:27.500 --> 02:17:32.208
go up because it's higher load and the January numbers

02:17:32.218 --> 02:17:35.029
would look very close to what our capacity for contract

02:17:35.039 --> 02:17:38.138
analysis looks like. So that highest number is gonna

02:17:38.148 --> 02:17:42.158
be around 20%. Are you gonna assume Elliott like through

02:17:42.167 --> 02:17:46.659
the entire winter season for the capacity for contract

02:17:46.668 --> 02:17:51.299
We will, for the moral, we will not, we'll have both

02:17:51.308 --> 02:17:54.088
of these in there. We'll have all the distribution

02:17:54.099 --> 02:17:57.569
of all the, all the outcomes on the left hand chart

02:17:57.579 --> 02:18:01.058
is our base and then we'll have the right hand chart

02:18:01.068 --> 02:18:04.347
for each, for January, for February. That shows what

02:18:04.359 --> 02:18:06.888
happens if a, uh Elliott style winter storm were to

02:18:06.898 --> 02:18:11.289
hit. Hey, hey, Pete, uh, your models assume the same

02:18:11.298 --> 02:18:14.369
Do they take into account controllable load resources

02:18:14.498 --> 02:18:15.518
Yes, and their behavior.

02:18:19.138 --> 02:18:20.870
So there's a lot of people shaking their heads behind

02:18:20.879 --> 02:18:22.569
you guys. Um Just so, you know,

02:18:24.679 --> 02:18:25.468
but, uh,

02:18:29.769 --> 02:18:31.870
I don't know, I think there's an argument developing

02:18:31.879 --> 02:18:34.110
over the weighting of winter storm Elliott, you know

02:18:34.120 --> 02:18:38.829
whether it will happen again, have in Pete or Woody

02:18:39.040 --> 02:18:41.668
have you taken into account your kind of most recent

02:18:41.679 --> 02:18:45.308
weather forecast and kind of computed that in with

02:18:45.319 --> 02:18:47.909
your models, in terms of what could theoretically be

02:18:47.918 --> 02:18:51.519
expected, it's a dangerous assumption. I understand

02:18:51.530 --> 02:18:54.750
But yeah, we've had discussions with, with Chris Coleman

02:18:54.759 --> 02:18:57.918
our meteorologist about incorporating, you know, a

02:18:57.929 --> 02:19:01.819
view of, of the upcoming weather. And that is very

02:19:01.829 --> 02:19:04.418
difficult. And in the slide, I'm going to show you

02:19:04.429 --> 02:19:08.290
later on there's a bullet, the text box that says you

02:19:08.299 --> 02:19:11.649
can have a mild winter and have an awful storm, winter

02:19:11.659 --> 02:19:16.299
storm happening. So you can't rely on a forecast. Yeah

02:19:16.308 --> 02:19:18.808
there's just no way to do it. But, you know, potentially

02:19:18.819 --> 02:19:22.000
we can certainly include some forecast information

02:19:22.088 --> 02:19:24.899
you know, in the mora for informational purposes. I

02:19:24.909 --> 02:19:28.318
I don't think you can really use it to drive the results

02:19:28.468 --> 02:19:30.667
because, yeah, but, but since we're doing this on a

02:19:30.677 --> 02:19:33.507
monthly basis, so that's a near term outlook and that

02:19:33.518 --> 02:19:35.898
was the whole point of, of trying to do it on a

02:19:36.039 --> 02:19:39.539
a very close period snapshot moving forward so that

02:19:39.548 --> 02:19:42.328
you could have something like that as a reference point

02:19:42.398 --> 02:19:46.158
I know it's variable. But, um, the beauty of the Mora

02:19:46.167 --> 02:19:47.888
now is we're doing it on a monthly basis. So you don't

02:19:47.898 --> 02:19:51.158
have that seasonal miss, uh, because you're not taking

02:19:51.167 --> 02:19:53.138
into account that entire threemonth season

02:19:55.200 --> 02:19:58.709
Well, and I would also add that as Commissioner McAdams

02:19:58.718 --> 02:20:00.540
said, there's an argument for me whether or not Winter

02:20:00.549 --> 02:20:03.579
storm Elliott is gonna happen again. I wouldn't argue

02:20:03.588 --> 02:20:05.388
against that. I mean, given all our extreme weather

02:20:05.399 --> 02:20:07.829
conditions, but, but I think there's also an argument

02:20:07.838 --> 02:20:10.530
forming that perhaps your first chart already includes

02:20:10.540 --> 02:20:13.509
some extreme weather impact and you, you, the risk

02:20:13.519 --> 02:20:18.769
is maybe not as high as the second chart. And so, um

02:20:19.149 --> 02:20:23.168
I think that's another argument, potentially um formulating

02:20:23.179 --> 02:20:25.709
as I see, you know, the talking heads in the background

02:20:27.509 --> 02:20:30.459
Well, I think we'll get into this when we talk about

02:20:30.468 --> 02:20:33.338
the capacity for contract, but that's a dramatic increase

02:20:34.558 --> 02:20:38.638
from 4 to 14% in December from, I'm not sure what the

02:20:38.649 --> 02:20:40.379
number will be for January, but it goes all the way

02:20:40.388 --> 02:20:45.218
up to 20%. So that's what we're highlighting here.

02:20:45.229 --> 02:20:49.338
That's why we did the capacity for contract that 20%

02:20:49.349 --> 02:20:53.519
risk is substantial. And that's, that's why we took

02:20:53.530 --> 02:20:55.299
this initiative. Got it.

02:20:58.079 --> 02:21:00.750
Ok. Any other questions?

02:21:03.019 --> 02:21:04.780
So I do, I guess I do have one question.

02:21:06.579 --> 02:21:07.450
It's bait. Uh

02:21:09.829 --> 02:21:11.799
So the uh

02:21:14.370 --> 02:21:22.899
on the right chart, 7 a.m. the uh 10% and the 8%

02:21:22.940 --> 02:21:24.899
are, um,

02:21:29.179 --> 02:21:32.679
so you say that 18% probability that we'll go into

02:21:32.790 --> 02:21:36.250
that we have a challenge based upon this model run

02:21:38.190 --> 02:21:38.808
Um

02:21:43.509 --> 02:21:48.409
I, is it, uh I don't know what my question is. Um

02:21:48.700 --> 02:21:52.049
I guess it's, is it fair to read that to say that

02:21:52.440 --> 02:21:57.409
uh 81% plus 8% is we have a 90% chance that we're

02:21:57.418 --> 02:22:01.950
not gonna go into an EE event.

02:22:04.190 --> 02:22:10.200
Well, more uh an ee a event of less than 2500 megawatts

02:22:11.229 --> 02:22:14.599
What's, what's missing from the chart is what happens

02:22:14.610 --> 02:22:21.579
between 5500, right? So if I added that column in there

02:22:21.649 --> 02:22:23.700
then you could add all the numbers together. and then

02:22:23.709 --> 02:22:26.739
you could say, OK, this, this is what the the probability

02:22:26.750 --> 02:22:29.870
of, of not getting into uh you know, an ee a or

02:22:29.879 --> 02:22:32.940
or getting into a, a control room advisory or something

02:22:32.950 --> 02:22:36.129
like that. So that's why I say at the bottom, the probabilities

02:22:36.138 --> 02:22:39.440
are, are not additive. So, uh you know, that's certainly

02:22:39.450 --> 02:22:42.049
a column you can include in here, you know that, but

02:22:42.058 --> 02:22:44.709
yeah, we want to, we want to just focus on the, the

02:22:44.718 --> 02:22:47.239
three columns that are, I think of most interest, right

02:22:47.250 --> 02:22:51.088
Is uh you know, a control room advisory, the 3000 and

02:22:51.099 --> 02:22:54.349
then getting into E A and then what happens with the

02:22:54.360 --> 02:22:58.429
the rotating outage and, and ha have you all seen over

02:22:58.440 --> 02:23:04.388
um y'all's decades of working in, in the utility business

02:23:04.399 --> 02:23:12.599
and, and in ERCOT um are, are we moving the ball to

02:23:12.610 --> 02:23:17.649
try to get um resource adequacy to eliminate an ee

02:23:17.659 --> 02:23:23.739
a event? Um historic as I understand it, historically

02:23:23.750 --> 02:23:28.599
ee a events were cautionary events on the system that

02:23:28.649 --> 02:23:32.829
that required unique actions but they weren't, they

02:23:32.838 --> 02:23:36.588
weren't immediate crisis, they're not loaded. They

02:23:36.599 --> 02:23:40.209
are not load shed. Are we moving that ball from the

02:23:40.218 --> 02:23:44.138
load shed? Ee A three and taking the actions that we

02:23:44.149 --> 02:23:48.610
used to take at three at one now? Yes. And why is

02:23:48.620 --> 02:23:52.759
that, that was a policy from the PUC?

02:23:54.308 --> 02:23:58.129
Which policy is that? Well, an example would be moving

02:23:58.138 --> 02:24:03.269
the ES out of EE A two and putting it before E

02:24:03.280 --> 02:24:09.149
A one. That's one example. So the, the moving ball

02:24:09.159 --> 02:24:15.079
was, don't go into ee A use some of your uh tools

02:24:15.379 --> 02:24:18.509
that you were saving in ee A in the past, use them

02:24:18.519 --> 02:24:21.918
before you get into EE A. So you could say that uh

02:24:21.929 --> 02:24:27.329
currently our toolbox, once we go in the EE A is a

02:24:27.379 --> 02:24:30.769
lot more empty than it used to be. So maybe, maybe

02:24:30.780 --> 02:24:33.179
we should, my view is maybe that's something that we

02:24:33.190 --> 02:24:35.819
should be looking at is, I mean, I think we saw it

02:24:35.829 --> 02:24:38.418
September 6. If you know, when we went straight to

02:24:38.860 --> 02:24:42.909
EE A two, what was left? We had already used RR S

02:24:42.968 --> 02:24:46.239
at three o'clock in the afternoon. So what, what's

02:24:46.250 --> 02:24:49.329
left? I mean, it's, it's a policy decision on how you

02:24:49.338 --> 02:24:53.739
want to do that. Well, ultimately, there's only the

02:24:53.899 --> 02:24:58.190
number of resources for the consideration in the discussion

02:24:58.200 --> 02:25:01.759
was the public was traumatized by Winter storm Urie

02:25:02.588 --> 02:25:06.459
I use the word traumatized. It keeps coming up in the

02:25:06.468 --> 02:25:10.468
press the legislature, everybody remembers it. And

02:25:10.479 --> 02:25:14.388
so the, the theory was as a part of our workshops of

02:25:14.399 --> 02:25:19.110
the past, why these are useful is that when they receive

02:25:19.120 --> 02:25:23.379
the eea notice they're going to pay attention. I did

02:25:23.388 --> 02:25:26.049
at ee a too, I paid attention to that. I was wondering

02:25:26.058 --> 02:25:28.218
what was going on on September 7th

02:25:30.138 --> 02:25:36.769
six. Yeah. So, and that they would conserve, but we

02:25:36.780 --> 02:25:41.000
have gone into a period where we have sent out a number

02:25:41.009 --> 02:25:44.360
of alerts. So the question becomes, is the public becoming

02:25:44.370 --> 02:25:46.950
desensitized to our messaging and that's something

02:25:46.959 --> 02:25:50.694
we're going to have to adapt and, and tangle with over

02:25:50.704 --> 02:25:53.884
the next year. Can I ask a follow up question from

02:25:53.894 --> 02:25:55.884
Commissioner Glotfelty? And that is since you opened

02:25:55.894 --> 02:25:59.584
the door for more questions, I'm sorry, in your analysis

02:25:59.593 --> 02:26:03.284
of, you know, e A one level and the risk involved.

02:26:03.293 --> 02:26:06.304
Do you factor in all the tools that we have in our

02:26:06.315 --> 02:26:09.165
toolbox that we used prior to getting to E A one level

02:26:09.534 --> 02:26:14.125
Yes, dispatch of all our ancillaries and yes, and we

02:26:14.134 --> 02:26:18.450
look at the monthly values, the requirements. Um So

02:26:18.459 --> 02:26:21.429
those are the main inputs in the model. So, yeah, es

02:26:21.440 --> 02:26:23.690
and all the other goodies.

02:26:27.558 --> 02:26:31.218
Can I make a comment? Uh Commissioner Gel about the

02:26:31.489 --> 02:26:34.079
you know, this issue about, you know, ee A and how

02:26:34.088 --> 02:26:38.129
quickly went into EE A too. So, you know, with all

02:26:38.138 --> 02:26:40.399
the additional wind and solar, you have, you know,

02:26:40.409 --> 02:26:44.019
much greater ramping. So I don't think you have that

02:26:44.489 --> 02:26:47.739
kind of period where you can, where the operators can

02:26:47.750 --> 02:26:50.780
figure out what's going on and, and do a lot of advanced

02:26:50.790 --> 02:26:53.780
planning all of a sudden you've got that ramp and so

02:26:53.790 --> 02:26:56.700
decisions have to be made really quickly. And so I

02:26:56.709 --> 02:26:58.769
think that's a, you know, another issue with the EE

02:26:58.780 --> 02:27:01.509
A that you want to be, you know, advised sooner than

02:27:01.519 --> 02:27:04.599
we have in the past just because of those ramps. Right

02:27:04.739 --> 02:27:07.588
And does that, does the pendulum swing back a little

02:27:07.599 --> 02:27:10.558
bit, the more batteries that you have because they're

02:27:10.569 --> 02:27:14.399
almost instantaneous. So there's no ramp or, or kind

02:27:14.409 --> 02:27:17.558
of sub second ramp on a battery. Yeah, that, that would

02:27:17.569 --> 02:27:20.989
that would definitely help. But in the long term, as

02:27:21.000 --> 02:27:23.780
you add more battery capacity, the the reliability

02:27:23.790 --> 02:27:26.780
benefit goes down. So there's a certain point where

02:27:26.790 --> 02:27:30.489
you saturate and that, that benefit, the marginal benefit

02:27:30.500 --> 02:27:33.040
goes down. So we're not going to see that for quite

02:27:33.049 --> 02:27:36.190
a while, but maybe three or four years from now, you

02:27:36.200 --> 02:27:38.549
you'll see that we, we've maxed out on the benefit

02:27:38.558 --> 02:27:42.549
I just, I, I have a hard time getting my head around

02:27:42.638 --> 02:27:46.229
kind of the whole the concept of the ELC and that the

02:27:46.239 --> 02:27:50.849
concept of that I get it when it's static. If it's

02:27:50.860 --> 02:27:53.989
a static, you know, two dimensional piece of paper

02:27:54.088 --> 02:27:58.500
you know that the next Megawatt of wind, if you've

02:27:58.509 --> 02:28:01.679
met all of your, your load, then the next Megawatt

02:28:01.690 --> 02:28:05.558
of wind has no value because everything is met. But

02:28:05.569 --> 02:28:09.569
when you have, when every one of these dynamics is

02:28:09.579 --> 02:28:13.329
changing in terms of load mostly. But then in terms

02:28:13.338 --> 02:28:16.899
of outages and in terms of, you know, solar. So you've

02:28:16.909 --> 02:28:19.540
got a cloud going over a solar plant in terms of a

02:28:19.690 --> 02:28:21.870
you have a battery that discharged and then didn't

02:28:21.989 --> 02:28:26.950
the, the EL C is not a static number. I think operationally

02:28:26.959 --> 02:28:31.058
on a daily basis, it moves every, I don't know, maybe

02:28:31.069 --> 02:28:34.849
every, every minute. So it's hard for me to get my

02:28:34.860 --> 02:28:41.429
head around using a s the same number for a long term

02:28:41.479 --> 02:28:44.940
You can't. Ok. Yeah, absolutely. And, and the way we're

02:28:44.950 --> 02:28:48.549
we're gonna be working with these uh it's called a

02:28:48.558 --> 02:28:52.299
surface but, but basically you look at your portfolio

02:28:52.308 --> 02:28:56.079
and your, your load and based on what those are at

02:28:56.088 --> 02:29:00.379
that time, you can pull out an LC value that matches

02:29:00.388 --> 02:29:04.338
up with all that. So it's a dynamic. So in the CDR

02:29:04.349 --> 02:29:07.679
report, for example, you'll see El CS, you know, bouncing

02:29:07.690 --> 02:29:11.110
around to reflect changes in the portfolio. So that's

02:29:11.120 --> 02:29:13.950
a huge benefit. And then on the on the batteries, I

02:29:14.120 --> 02:29:17.769
just want to follow up with that. So you will have

02:29:17.780 --> 02:29:21.149
to depend on longer duration batteries. So again, you

02:29:21.159 --> 02:29:24.569
can continue to get the benefit of the batteries. But

02:29:24.579 --> 02:29:27.610
over time, you'll have to rely on those longer duration

02:29:27.620 --> 02:29:31.019
batteries, right? I mean, I think what you have is

02:29:31.030 --> 02:29:33.479
if you've got a onehour battery that discharges for

02:29:33.489 --> 02:29:37.629
one hour and then if you have a 100 Megawatt battery

02:29:37.638 --> 02:29:40.950
that discharges for one hour and depletes and you've

02:29:40.959 --> 02:29:44.500
got another 100 Megawatt hour for the next hour, it's

02:29:44.509 --> 02:29:47.569
still the same number of Megawatt hour producing. But

02:29:47.579 --> 02:29:50.229
one facility is gone and the other one's there. If

02:29:50.239 --> 02:29:52.468
there's, if they're consecutive on top of each other

02:29:52.479 --> 02:29:56.838
then you've got twice as much. So, is there any relationship

02:29:56.849 --> 02:30:01.759
between the ELC and transmission if you're able to

02:30:01.769 --> 02:30:05.940
access more of the resource? Well, we did a study,

02:30:06.269 --> 02:30:10.019
uh a deliverability study that looked at transmission

02:30:10.030 --> 02:30:13.690
constraints and you could tie that in, you know, to

02:30:13.700 --> 02:30:17.500
ELC. Uh So we haven't done that directly. We've just

02:30:17.509 --> 02:30:21.718
looked at uh what happens if you're uh relaxed constraints

02:30:22.200 --> 02:30:25.700
uh between regions and RCO OT or, or, or you build

02:30:25.709 --> 02:30:29.179
resources in a certain region and is that able to,

02:30:29.190 --> 02:30:32.159
to maintain your reliability level that, that you start

02:30:32.168 --> 02:30:35.899
off with? So that was a kind of a proof of concept

02:30:36.360 --> 02:30:40.450
but you can carry that through potentially to CS. So

02:30:40.620 --> 02:30:43.629
that's sort of ongoing discussions with our consultants

02:30:43.700 --> 02:30:46.209
to see, you know, how we can do that. And then also

02:30:46.218 --> 02:30:48.638
on the, you know, the thermal side, you know, we're

02:30:48.649 --> 02:30:52.009
looking at having L CS for thermal generators as well

02:30:52.899 --> 02:30:55.838
So Pete as we kind of close out the um more preview

02:30:56.120 --> 02:30:59.019
uh I know at the top, we talked about, um, you know

02:30:59.030 --> 02:31:01.879
the change and this being kind of like the first time

02:31:01.888 --> 02:31:04.849
that we are looking at it on a monthly basis versus

02:31:04.989 --> 02:31:07.500
you know, a more seasonal basis. But there also was

02:31:07.509 --> 02:31:10.459
a change in, in terms of um, the way that we are

02:31:10.468 --> 02:31:13.530
are, are projecting probability. And so, could you

02:31:13.540 --> 02:31:16.790
just very quickly kind of contrast what we're doing

02:31:16.799 --> 02:31:20.280
now in this approach to the more regard, not only to

02:31:20.290 --> 02:31:22.829
monthly but probability before we kind of move on to

02:31:22.838 --> 02:31:25.649
the next item. Well, you're stealing my thunder for

02:31:25.659 --> 02:31:28.519
my later presentation. That's fine. Just hold it. That's

02:31:28.709 --> 02:31:31.780
fine. That thought. Ok, we, we'll move on to the next

02:31:31.790 --> 02:31:36.558
one. So any more questions, you know? Ok. Thank you

02:31:36.569 --> 02:31:39.519
so much. Thank you, Pete. So we are going, I just want

02:31:39.530 --> 02:31:42.870
to remind you, we are about 25 30 minutes behind schedule

02:31:42.879 --> 02:31:43.338
but

02:31:45.450 --> 02:31:45.588
ii, a

02:31:49.149 --> 02:31:52.129
lot of ground, we are switching subjects. Now we are

02:31:52.138 --> 02:31:53.979
gonna go demand response programs.

02:31:56.530 --> 02:31:59.399
Uh OK. It's up to you. Do you wanna break 10 minutes

02:31:59.409 --> 02:32:02.799
now or after this panel? Let's keep going and then

02:32:02.808 --> 02:32:03.700
we'll, we'll do a little bit.

02:32:05.468 --> 02:32:09.729
So first panel is ERCOT Mark Patterson. Yeah, Mark

02:32:09.739 --> 02:32:11.819
Patterson, manager of demand integration

02:32:15.468 --> 02:32:18.338
start off by talking a little bit about demand response

02:32:18.349 --> 02:32:22.370
for this winter. What can we expect? And I'll get into

02:32:22.379 --> 02:32:24.549
a little bit about the settlement, only distributed

02:32:24.558 --> 02:32:28.860
generators. Um, starting off with the emergency response

02:32:28.870 --> 02:32:34.799
service. I've provided a table here that shows um the

02:32:34.808 --> 02:32:39.179
the two previous winner standard contract terms um

02:32:39.190 --> 02:32:44.179
for es that's runs from December through March of the

02:32:44.190 --> 02:32:48.979
next year. So I've got the two previous standard contract

02:32:48.989 --> 02:32:51.739
terms and the upcoming standard contract term, which

02:32:51.750 --> 02:32:54.888
we will not be procuring for for about another three

02:32:54.899 --> 02:32:58.659
weeks. So the first two, those are actual procurement

02:32:58.668 --> 02:33:03.099
um values quantities and those are all in megawatts

02:33:03.739 --> 02:33:06.299
and, and then for the December through March again

02:33:06.308 --> 02:33:10.308
those are estimated uh for the upcoming winter. And

02:33:10.319 --> 02:33:15.040
it's based on last year's actual procurement, but I've

02:33:15.049 --> 02:33:20.040
increased them by, by 3% growth based on what I saw

02:33:20.049 --> 02:33:23.709
this summer procurement from the previous year's summer

02:33:23.718 --> 02:33:27.299
So that's how it came up with the numbers. Um I've

02:33:27.308 --> 02:33:30.540
highlighted what we call time periods, one and two

02:33:30.968 --> 02:33:34.360
and time periods. Four and five because one and two

02:33:34.370 --> 02:33:37.479
kind of correlates with the morning ramp period and

02:33:37.489 --> 02:33:40.149
then time periods four and five would correlate with

02:33:40.159 --> 02:33:43.870
the afternoon ramp period. So I think what's what I

02:33:43.879 --> 02:33:47.120
kind of want to bring your attention other than showing

02:33:47.129 --> 02:33:50.838
you, here's the quantities that we're expecting. Um

02:33:50.849 --> 02:33:53.888
The question has come up about a year ago, the commission

02:33:53.899 --> 02:33:57.940
increased the annual budget of es from $50 million

02:33:57.950 --> 02:34:01.360
to 75 million. So you're probably understand, are we

02:34:01.370 --> 02:34:05.638
realizing an increase in, in the capacity being offered

02:34:06.058 --> 02:34:09.629
Well, you can see from the first year uh the 2021 to

02:34:09.638 --> 02:34:14.588
2022 to last year, which last year was the first year

02:34:14.649 --> 02:34:17.780
of procurement for the winner. Just following that

02:34:17.790 --> 02:34:21.929
increase, there wasn't any real significant increase

02:34:21.940 --> 02:34:24.968
in the amount that was offered and procured. And I

02:34:24.979 --> 02:34:27.209
think I even communicated to the commission when they

02:34:27.218 --> 02:34:29.308
were doing it. I didn't think there was really going

02:34:29.319 --> 02:34:31.649
to be enough time for the Qs CS to go out there

02:34:31.659 --> 02:34:34.319
and contract for additional capacity. And it's pretty

02:34:34.329 --> 02:34:39.088
much what we saw um, this year. I'm, I'm again, the

02:34:39.099 --> 02:34:42.530
only thing I'm doing is I'm projecting about a 3% increase

02:34:42.968 --> 02:34:46.379
But I will tell you, um we've had some recent discussions

02:34:46.388 --> 02:34:50.049
with some additional Qs CS that I think we'll even

02:34:50.058 --> 02:34:53.808
see an additional bump of maybe 50 to 100 megawatts

02:34:53.819 --> 02:34:58.638
this winter above what I'm even showing here. Um And

02:34:58.649 --> 02:35:00.659
I wanted to reflect these numbers because these numbers

02:35:00.668 --> 02:35:03.500
are what I've provided to Pete, which you would see

02:35:03.509 --> 02:35:06.209
in his reports. So I didn't want you to see why am

02:35:06.218 --> 02:35:08.280
I showing a different number here from what, what you

02:35:08.290 --> 02:35:10.500
would see in Pete's reports. But I'm just saying, I

02:35:10.509 --> 02:35:14.019
think we could see a 50 to 100 Megawatt increase above

02:35:14.030 --> 02:35:18.149
what I, what I'm showing here. Ok. Now, the one big

02:35:18.159 --> 02:35:22.759
unknown I wanted to point out is um the T DS B

02:35:22.769 --> 02:35:26.179
load management programs have historically been a summer

02:35:26.190 --> 02:35:30.409
only program. And I think we're pretty aware that uh

02:35:30.418 --> 02:35:34.129
during the summer those pro those programs do compete

02:35:34.138 --> 02:35:36.700
directly with the emergency response service. They

02:35:36.709 --> 02:35:40.388
generally attract or target the same types of loads

02:35:40.849 --> 02:35:44.308
Um And now the T DS B load management, they're even

02:35:44.319 --> 02:35:48.200
moving and having winter programs as well. So, I don't

02:35:48.209 --> 02:35:52.468
know, I don't know if, how much of those programs may

02:35:52.479 --> 02:35:55.349
have an impact on, on what I'm forecasting here. Just

02:35:55.360 --> 02:35:58.718
don't have enough experience because of the new program

02:35:58.729 --> 02:36:01.399
the winter programs that they're offering. Ok.

02:36:03.040 --> 02:36:05.190
Um And the last bullet I think has already been kind

02:36:05.200 --> 02:36:07.610
of noted. Just wanted to mention though that the emergency

02:36:07.620 --> 02:36:11.030
response service is, is deployed when the PR C drops

02:36:11.040 --> 02:36:16.030
to 3000. Ok. Change slide, please. Um Another thing

02:36:16.040 --> 02:36:18.700
that I thought may have been interest is well, are

02:36:18.709 --> 02:36:23.200
we procuring everything that is being offered? And

02:36:23.209 --> 02:36:27.649
I've gone back for starting in December of last year

02:36:27.659 --> 02:36:31.870
for the last four standard contract terms. And this

02:36:31.879 --> 02:36:35.049
is the uh there's time periods, one through eight,

02:36:35.058 --> 02:36:37.950
those are defined time periods for which we procure

02:36:37.959 --> 02:36:43.209
Es we, we allocate the $75 million a year out to the

02:36:43.218 --> 02:36:45.968
risk that we associate with each time period for each

02:36:45.979 --> 02:36:49.819
standard contract term. And we procure up to that amount

02:36:49.829 --> 02:36:53.329
that we designate in the RP that we allocated as a

02:36:53.338 --> 02:36:58.569
portion of that $75 million we will procure up to um

02:36:59.280 --> 02:37:03.450
historically, we procured up to that spin limit. Um

02:37:03.459 --> 02:37:06.808
But what we started saying once the the the annual

02:37:06.819 --> 02:37:10.349
budget went to 50 million to 75. We were starting to

02:37:10.360 --> 02:37:15.450
observe some, some offers that if we would have procured

02:37:15.459 --> 02:37:19.229
the next offer, it would have cost a substantial amount

02:37:19.239 --> 02:37:22.929
of more money that didn't really bring that much additional

02:37:22.940 --> 02:37:26.700
capacity uh to to the service for that period. And

02:37:26.709 --> 02:37:30.879
we, we kind of consider that as, as unreasonable offer

02:37:30.888 --> 02:37:33.299
and we didn't procure it. So what I've shown here on

02:37:33.308 --> 02:37:36.040
this table here is those are all in Megawatt values

02:37:36.049 --> 02:37:38.799
for each standard contract term and each time period

02:37:38.968 --> 02:37:42.079
what the capacity was that we did not procure that

02:37:42.088 --> 02:37:44.759
was offered. And there's two reasons why we wouldn't

02:37:44.769 --> 02:37:47.110
have procured it. One is if we would have procured

02:37:47.120 --> 02:37:49.239
that capacity, it may have, it would have put us over

02:37:49.250 --> 02:37:52.959
the spin limit for that time period or we designated

02:37:52.968 --> 02:37:55.319
it as being an unreasonable offer for the reason I

02:37:55.329 --> 02:38:00.040
just just mentioned. So I want my real point is in

02:38:00.049 --> 02:38:03.280
most every case, we're procuring pretty much everything

02:38:03.290 --> 02:38:05.700
that that's, that's being offered. There's a few outliers

02:38:05.709 --> 02:38:08.799
but there's reasons why we opted not to procure those

02:38:08.808 --> 02:38:13.138
for those time periods or during those standard contract

02:38:13.149 --> 02:38:16.599
terms. And we've communicated that to the commission

02:38:16.989 --> 02:38:20.799
All right, let's move on to the next slide. Now, we're

02:38:20.870 --> 02:38:23.409
going, can I ask you sure, can I just rephrase something

02:38:23.418 --> 02:38:25.259
that you shouldn't tell me if I'm right or wrong? You

02:38:25.269 --> 02:38:27.888
procured everything that you think is reasonable in

02:38:27.899 --> 02:38:33.030
terms of cost. Yes, sir. Ok. Yes. Yeah, up to, well

02:38:33.040 --> 02:38:35.790
up to the spend limit, we still wouldn't exceed that

02:38:35.799 --> 02:38:38.729
spend limit that we designated for that time period

02:38:39.338 --> 02:38:43.569
Ok. All right. Now, let's move on to the load resources

02:38:45.190 --> 02:38:49.329
So I've, uh, again, I'm kind of using the same periods

02:38:49.338 --> 02:38:52.610
uh, December of this year and the first three months

02:38:52.620 --> 02:38:57.718
of, of 2024. Uh, these are the numbers that we've projected

02:38:57.729 --> 02:39:01.379
uh that we will see participating in the various services

02:39:01.759 --> 02:39:04.700
Um Let's start off with the first one. These are the

02:39:04.709 --> 02:39:07.290
noncontrolled load resources, providing responsive

02:39:07.299 --> 02:39:12.099
reserve service. Um This value, these values here are

02:39:12.110 --> 02:39:16.530
these are what's being reflected here is the ERCOT

02:39:18.668 --> 02:39:23.418
obligation for, for over the peak hours for that um

02:39:23.929 --> 02:39:27.879
for that month. Um Minus though there's a, a

02:39:30.918 --> 02:39:34.138
requirement that a certain amount of responsive reserve

02:39:34.149 --> 02:39:37.418
services must be carried by resources that can provide

02:39:37.429 --> 02:39:41.290
PFR. So we have to back that out. And so the remainder

02:39:41.299 --> 02:39:44.269
is the amount that can be procured by the load resources

02:39:44.280 --> 02:39:46.370
So that's the values that you're seeing here, the 17

02:39:46.379 --> 02:39:50.909
23 for December and then March, February, January,

02:39:50.918 --> 02:39:53.558
February and March, you'll see a slight increase and

02:39:53.569 --> 02:39:56.849
that's because the requirement changed about how much

02:39:56.860 --> 02:40:02.968
has to be carried on a PFR type resources. Um The other

02:40:02.979 --> 02:40:06.040
points that I want to mention though, about the response

02:40:06.049 --> 02:40:11.599
of reserve of the RR S is that there's um about 700

02:40:11.610 --> 02:40:15.700
megawatts typically during this period that we observed

02:40:15.709 --> 02:40:19.909
that I call them willing participants, this is capacity

02:40:19.918 --> 02:40:23.308
that's being offered into the service. But we're having

02:40:23.319 --> 02:40:27.519
to pro write those offers um to stay underneath these

02:40:27.530 --> 02:40:30.668
these constraints. So I call them willing participants

02:40:30.679 --> 02:40:33.379
There's 700 megawatts, you could call it stranded out

02:40:33.388 --> 02:40:35.899
there that want to participate in the service. But

02:40:35.909 --> 02:40:37.718
they can't because of the limits that you're seeing

02:40:37.729 --> 02:40:38.110
here.

02:40:39.819 --> 02:40:42.579
But that's it because they can't physically comply

02:40:42.588 --> 02:40:47.168
with the profile limits or by, by, by that, they would

02:40:47.179 --> 02:40:50.479
we would be exceeding the amount. There's, there's

02:40:50.489 --> 02:40:53.450
the obligation, the limit obligation and how much they

02:40:53.459 --> 02:40:56.649
can, that can be covered by these resources. So around

02:40:56.679 --> 02:40:59.280
them and they're all offering at the same price. So

02:40:59.290 --> 02:41:01.979
you have to, you prorate all of those offers down to

02:41:01.989 --> 02:41:05.239
meet these limits again, that's about 700 megawatts

02:41:05.759 --> 02:41:09.450
And then the uh the other factor is, which I think

02:41:09.459 --> 02:41:13.468
is notable is, is um these resources can also carry

02:41:13.479 --> 02:41:18.269
up to 100 150% of their obligation. And when they do

02:41:18.280 --> 02:41:21.668
that and they show that they can get paid the price

02:41:21.679 --> 02:41:26.209
ADDers. But what we've observed is during periods of

02:41:26.218 --> 02:41:31.269
potential higher risk, they're not carrying that additional

02:41:31.489 --> 02:41:34.819
uh additional capacity. So it's, I'm just saying that's

02:41:34.829 --> 02:41:37.690
not, we're not seeing that additional being provided

02:41:37.700 --> 02:41:40.500
to the, into the, into the market as well.

02:41:42.099 --> 02:41:45.280
All right, then moving on to the uh well, no, no let's

02:41:45.290 --> 02:41:47.239
stay on. We had to finish the other services. We have

02:41:47.250 --> 02:41:50.329
the non controls, providing nonspin. We're seeing very

02:41:50.338 --> 02:41:53.440
very little participation from control from non control

02:41:53.540 --> 02:41:56.519
load resources providing nonspin just hasn't been much

02:41:56.530 --> 02:42:01.259
interest in it at all. Um And then the resource is

02:42:01.269 --> 02:42:03.599
providing cr s that's a new service that just went

02:42:03.610 --> 02:42:07.959
into effect this summer. We're seeing about 224. I

02:42:07.968 --> 02:42:11.149
think the interest just keeps building, but that's

02:42:11.159 --> 02:42:14.040
what we're projecting right now for this summer, for

02:42:14.049 --> 02:42:17.120
this winter. I'm sorry about the lack of the lack of

02:42:17.129 --> 02:42:21.599
interest on nonspin. Um We've heard a good question

02:42:22.290 --> 02:42:26.280
We've heard from a few Qs CS. It's because right now

02:42:26.588 --> 02:42:30.718
they get treated as offline nonspin. In other words

02:42:30.729 --> 02:42:32.950
they have to wait to get the instruction from URCO

02:42:33.729 --> 02:42:37.450
before they can get their price struck. Uh Their, their

02:42:37.459 --> 02:42:40.209
bid to buy, struck and deploy, they're having to wait

02:42:40.218 --> 02:42:43.659
for the instruction where if they were online, which

02:42:43.668 --> 02:42:47.000
there's an nrr that's been approved. But, uh it's not

02:42:47.009 --> 02:42:50.269
implemented then they, they, they have a standing,

02:42:50.280 --> 02:42:53.429
basically a standing bid to buy out there. And whenever

02:42:53.440 --> 02:42:56.968
that bid to buy struck, they could, they would see

02:42:57.019 --> 02:43:00.000
they would be able to reduce their, their load in response

02:43:00.009 --> 02:43:03.588
to those higher prices. So that's at least I, I'm not

02:43:03.599 --> 02:43:06.790
sure if that's the entire answer, but that's some of

02:43:06.799 --> 02:43:09.979
the responses that we've heard from some of the Qs

02:43:09.989 --> 02:43:13.918
CS. If we move to, to them being treated as online

02:43:13.929 --> 02:43:16.399
We would see more participation. I don't know how to

02:43:16.409 --> 02:43:19.379
quantify what more is, but we would see more participation

02:43:19.808 --> 02:43:20.440
Ok. Ok.

02:43:21.979 --> 02:43:24.360
And then the last bucket we've got here is the, uh

02:43:24.489 --> 02:43:27.280
this is the only group where the controllable load

02:43:27.290 --> 02:43:30.929
resources. Uh And I'm showing both those that are participating

02:43:30.940 --> 02:43:34.269
in S and, er, S and ECRS together at about 100 and

02:43:34.280 --> 02:43:36.918
20 megawatts. And I just grouped those because they're

02:43:36.929 --> 02:43:40.110
technically, they're deployed really it together uh

02:43:40.218 --> 02:43:42.879
under the same, same instructions.

02:43:44.588 --> 02:43:47.479
All right, I think that covered this and my next slide

02:43:47.489 --> 02:43:50.799
is just almost saying everything. I've, I've just got

02:43:50.819 --> 02:43:54.399
to communicating. So let's move on to now my next slide

02:43:54.989 --> 02:43:59.049
So now, um iii I don't not gonna take credit for this

02:43:59.058 --> 02:44:03.569
Um I'm gonna share a few points of a presentation,

02:44:03.579 --> 02:44:06.500
uh an analysis and a presentation that Kl Reich uh

02:44:06.989 --> 02:44:09.750
put together and he made the R MS on, on June of

02:44:09.759 --> 02:44:13.349
this past year. This had to do with his analysis of

02:44:13.360 --> 02:44:16.558
uh winter storm Elliott. He was trying to identify

02:44:16.569 --> 02:44:23.519
how much response that we observed from the rep programs

02:44:23.860 --> 02:44:30.690
during that event. I want to also say the uh the, the

02:44:30.700 --> 02:44:35.620
group of, of race or, or assets sites that, that he

02:44:35.629 --> 02:44:39.450
looked at. He, he identified the easy I DS that were

02:44:39.579 --> 02:44:44.450
non weather sensitive um and were on index pricing

02:44:44.870 --> 02:44:49.450
that the reps identified in their annual surveys and

02:44:49.459 --> 02:44:53.588
also those that were identified as being four CP responders

02:44:53.808 --> 02:44:58.250
So that's the group of easy I DS that he was looking

02:44:58.259 --> 02:45:02.088
at. He tried to look at, he attempted to look at me

02:45:02.179 --> 02:45:06.409
loads and the weather sensitive sites as well. And

02:45:06.418 --> 02:45:09.009
from what I understand from him is, is, is he just

02:45:09.019 --> 02:45:11.799
couldn't come up with a conclusive answer that he felt

02:45:11.808 --> 02:45:14.918
comfortable sharing any numbers with. So, so that's

02:45:14.929 --> 02:45:17.179
not going to be included in, in, in what I'm getting

02:45:17.190 --> 02:45:19.308
ready to show you. So now let's go to the next slide

02:45:20.909 --> 02:45:25.290
All right. So this is AAA graphic of, of the event

02:45:25.299 --> 02:45:30.159
uh with um uh mapping out graphing out the, the load

02:45:30.168 --> 02:45:34.049
from, from that group of easy ID. Si think the points

02:45:34.058 --> 02:45:38.129
I really want to bring up is, is um uh prices started

02:45:38.138 --> 02:45:44.370
to get elevated on December 22nd. Um uh December 20

02:45:44.379 --> 02:45:48.750
23rd is when the event really started to kick in. Um

02:45:48.870 --> 02:45:52.030
the highest prices, uh prices started to really elevate

02:45:52.040 --> 02:45:55.888
late late in the day on the 23rd and then on the

02:45:55.899 --> 02:45:58.968
24th, I think I understand the prices peaked around

02:45:58.979 --> 02:46:03.750
10 a.m. in the morning. Um The peak though reduction

02:46:03.759 --> 02:46:07.489
in this group of easy I DS he showed was about 3700

02:46:07.500 --> 02:46:11.370
megawatts that occur on the Friday. Uh a little less

02:46:11.379 --> 02:46:14.888
on Saturday at 3300 megawatts and even a little less

02:46:14.899 --> 02:46:20.599
than that on, on December 25th at 3000 megawatts. Um

02:46:20.940 --> 02:46:23.968
But yeah, so, so you say, well, we can maybe we can

02:46:23.979 --> 02:46:27.058
expect if we have a similar type of event, 3700 megawatts

02:46:27.069 --> 02:46:29.879
But you have to take into consideration Friday is a

02:46:30.250 --> 02:46:33.429
uh the day before a, not only a weekend but also the

02:46:33.440 --> 02:46:36.049
day before a holiday weekend. So he wanted to take

02:46:36.058 --> 02:46:39.429
out what the normal load reduction would have been

02:46:39.440 --> 02:46:42.338
So he estimated that and if you go to the next slide

02:46:42.349 --> 02:46:46.129
he's, he's estimated that to be about 250 megawatts

02:46:46.429 --> 02:46:50.620
So, so if the point is though, if we uh see a

02:46:50.629 --> 02:46:53.459
similar type of event this coming winter, uh we may

02:46:53.468 --> 02:46:57.250
see up about 3400 and 50 megawatts of response from

02:46:57.259 --> 02:47:01.370
these rep programs. But he also wanted to note we've

02:47:01.379 --> 02:47:03.509
already started seeing an increase in the amount of

02:47:03.519 --> 02:47:05.729
crypto loads coming on to the system. That should be

02:47:05.739 --> 02:47:09.280
price responsive. So this probably 34 50 should be

02:47:09.290 --> 02:47:12.269
considered a pretty conservative conservative number

02:47:12.280 --> 02:47:15.819
if you want to look forward to this winter. Ok.

02:47:17.709 --> 02:47:22.049
All right. My last uh, uh, group of slides, I wanted

02:47:22.058 --> 02:47:24.649
to show you the settlement only distributed generators

02:47:24.799 --> 02:47:29.058
So these are small generators that, that have to, they

02:47:29.069 --> 02:47:31.500
are 10 megawatts or less. But if they're one mega,

02:47:31.620 --> 02:47:34.950
if they're um greater than one Megawatt that they,

02:47:35.280 --> 02:47:37.149
and they inject onto the grid, they're required to

02:47:37.159 --> 02:47:40.739
register with ERCOT. If they're less than one Megawatt

02:47:40.879 --> 02:47:43.069
they're not required to register with ERCOT. But if

02:47:43.079 --> 02:47:45.549
they want to get paid for any energy that they inject

02:47:45.558 --> 02:47:48.659
onto the grid, they have to register as well. So the

02:47:48.668 --> 02:47:51.149
graph is going to be about settlement only generators

02:47:51.819 --> 02:47:54.418
Um And again, these settlement only generators of these

02:47:54.429 --> 02:47:56.870
can't participate in SCED, they can't participate in

02:47:57.149 --> 02:47:59.918
ancillary services. All they do is when they have excess

02:47:59.929 --> 02:48:02.519
energy they want to export onto the grid for whatever

02:48:02.530 --> 02:48:06.079
reason. Generally, it's in response to prices, then

02:48:06.088 --> 02:48:09.940
they can get compensated for for, for that energy N

02:48:09.989 --> 02:48:15.599
Pr R 9 17 back. What about three years ago um set

02:48:15.610 --> 02:48:19.888
that settlement only generators prior to that, they

02:48:19.899 --> 02:48:23.709
always received a zonal price for that energy. And

02:48:23.718 --> 02:48:29.299
N pr 9 17 moved them to Nodal pricing. But a group

02:48:29.308 --> 02:48:33.679
a subset of those could be grandfathered in as, as

02:48:33.690 --> 02:48:38.200
under zonal for a period of time that any new sodgs

02:48:38.209 --> 02:48:41.808
um are or will be priced at Nodal or in other words

02:48:41.819 --> 02:48:44.168
responding to a Nodal price, what was the magnitude

02:48:44.179 --> 02:48:46.540
of the grandfather getting ready to show you on the

02:48:46.549 --> 02:48:49.888
next slide? All right. So let's go to the next slide

02:48:49.899 --> 02:48:53.388
is now the graphic of. So here's historically how much

02:48:53.879 --> 02:48:57.030
the growth that we've seen in settlement only generators

02:48:57.088 --> 02:49:02.409
So um the first uh I wanna kind of the graphic is

02:49:02.418 --> 02:49:04.629
nice and everything but the two boxes really tell the

02:49:04.638 --> 02:49:08.440
story of the top left hand corner. Um total amount

02:49:08.450 --> 02:49:12.019
of settlement only generators is uh uh just a little

02:49:12.030 --> 02:49:16.349
less than 1000 megawatts, a little less than 400 resources

02:49:16.360 --> 02:49:20.099
You can see the split. Most of those are non, non renewable

02:49:20.110 --> 02:49:25.888
328 resources are, are non renewable and 52 are, are

02:49:25.899 --> 02:49:29.909
are renewable or storage the bottom. Then below that

02:49:29.918 --> 02:49:34.588
tells you that 100 and 66 of those remain zonal that

02:49:34.599 --> 02:49:39.558
represent just under 500 megawatts of total capacity

02:49:40.019 --> 02:49:42.829
And then we have the, the, the numbers that are, that

02:49:42.838 --> 02:49:45.250
are Nodal and that will continue to increase because

02:49:45.259 --> 02:49:49.120
any new sodgs will will have to be priced at Nodal

02:49:49.129 --> 02:49:53.088
Uh It's 214 of those and that's just a little less

02:49:53.099 --> 02:49:56.558
than, than, than the megawatts that we see at the zonal

02:49:56.569 --> 02:50:01.418
level. And that concludes what I prepared for today

02:50:03.009 --> 02:50:08.690
Any questions? Yes. Um Mark um you noted on page three

02:50:08.700 --> 02:50:13.209
of your presentation on the two reasons offer capacity

02:50:13.218 --> 02:50:18.530
was not procured and the top reason was because it

02:50:18.540 --> 02:50:22.918
would have exceeded the time period limit. I know we

02:50:22.929 --> 02:50:26.280
have the overall total budget cap. That's now I think

02:50:26.290 --> 02:50:30.030
70 million you mentioned. And so I wonder if it's possible

02:50:30.040 --> 02:50:33.329
to kind of take a more granular approach and how we

02:50:33.338 --> 02:50:36.588
allocate that funding on the time periods cause like

02:50:36.599 --> 02:50:38.569
in the winter, it's in the morning and, and the the

02:50:38.579 --> 02:50:43.468
ramp down in the summer, it's gross peak and ramp down

02:50:43.799 --> 02:50:46.509
is, is that something that y'all have looked at to

02:50:46.519 --> 02:50:51.009
to um maybe um try to procure more re resources on

02:50:51.019 --> 02:50:54.940
a more granular basis to target um when we would need

02:50:55.179 --> 02:50:57.979
the load resources. Well, and that's exactly what we

02:50:57.989 --> 02:51:00.888
actually do. So we have the different time periods

02:51:00.899 --> 02:51:03.819
all eight time periods. And I, so let's just take the

02:51:03.829 --> 02:51:07.530
winner, for example, the morning ramp is time periods

02:51:07.540 --> 02:51:12.129
one and two. What we do is we take again the $75

02:51:12.138 --> 02:51:16.269
million and we go to ERCOT operations and we, they

02:51:16.280 --> 02:51:20.530
allocate to us a risk. Their, their evaluation of risk

02:51:20.540 --> 02:51:23.780
for that standard contract term by each time period

02:51:23.879 --> 02:51:27.190
What is the risk of going into or needing this? This

02:51:27.200 --> 02:51:30.069
used to be going into an EE A now it's needing these

02:51:30.079 --> 02:51:34.179
resources and they will rate that as a risk from 1

02:51:34.190 --> 02:51:38.030
to 100 with 100 being the highest risk. So during the

02:51:38.040 --> 02:51:41.918
winter period, those morning hours will get a much

02:51:41.929 --> 02:51:44.838
higher risk factor. I don't think it's 100 I think

02:51:44.849 --> 02:51:48.159
it's like 80 or so in the morning hours compared to

02:51:48.168 --> 02:51:51.200
very, very low, maybe during the middle of the day

02:51:51.409 --> 02:51:55.349
or, and, or even at the weekend time periods, once

02:51:55.360 --> 02:51:58.838
those risk factors are assigned, we allocate much more

02:51:58.849 --> 02:52:03.718
money than out of that out that 50 million $75 million

02:52:03.729 --> 02:52:06.429
into those higher risk time periods than we do the

02:52:06.440 --> 02:52:10.679
lower risk that's sending the signal to the Qs CS we're

02:52:10.690 --> 02:52:13.540
willing to pay a lot more in these hours. So bring

02:52:13.549 --> 02:52:17.918
us as much capacity as, as you can uh by sending the

02:52:17.929 --> 02:52:21.979
price signal. So that's what we do is, is to try to

02:52:21.989 --> 02:52:25.959
be um more and more um

02:52:27.620 --> 02:52:30.668
I guess, precise and how we're allocating based on

02:52:30.679 --> 02:52:34.769
the risk, the need for that service. That's very helpful

02:52:34.780 --> 02:52:37.860
to understand. As I look at, you know, the different

02:52:37.870 --> 02:52:41.659
time periods and time period, one and two compared

02:52:41.668 --> 02:52:44.509
to time period, four and five, a little bit. But you

02:52:44.530 --> 02:52:47.079
have a mid one that's higher than the morning you want

02:52:47.088 --> 02:52:49.718
to go, but you want to go back to the previous slide

02:52:51.239 --> 02:52:53.338
Is that what you're talking about there? Yes, sir.

02:52:53.468 --> 02:52:54.299
Yeah. Yeah. Yeah.

02:52:57.540 --> 02:53:00.599
Um, so, I mean, we're sending the price signals now

02:53:00.610 --> 02:53:03.838
it doesn't necessarily equate to getting that much

02:53:03.849 --> 02:53:07.849
more. I mean, I, I'll be honest in most cases, these

02:53:07.860 --> 02:53:12.338
resources and there's a few of, uh, um, um,

02:53:14.200 --> 02:53:18.149
uh, there's a few outliers but generally es if you're

02:53:18.159 --> 02:53:21.968
gonna be providing the service you offer in almost

02:53:21.979 --> 02:53:25.649
every single time period, maybe not the weekends and

02:53:25.659 --> 02:53:28.299
time periods, six and seven are considered the weekend

02:53:28.308 --> 02:53:32.409
time periods, but one through five or, or like five

02:53:32.418 --> 02:53:34.709
I mean, those time periods run from five o'clock in

02:53:34.718 --> 02:53:37.655
the morning until 10 o'clock in the evening. So Mondays

02:53:37.665 --> 02:53:41.194
through Fridays. So that's the work day and generally

02:53:41.204 --> 02:53:44.513
the, the daylight hours covers the ramps time periods

02:53:44.524 --> 02:53:47.235
Eight is the overnight hours. So we, we've carved that

02:53:47.245 --> 02:53:50.713
off separately, but six and seven is the weekend, six

02:53:50.724 --> 02:53:53.894
is the morning ramp on a weekend seven is the uh the

02:53:53.905 --> 02:53:55.954
afternoon ramp on the weekend,

02:53:57.579 --> 02:54:01.718
but we tried to send the right price signal. Thank

02:54:01.729 --> 02:54:03.509
you. Thank you for that explanation. It's very helpful

02:54:03.519 --> 02:54:07.870
to understand and I also um glad you noted um about

02:54:07.879 --> 02:54:11.360
how even though we increase the budget cap from 50

02:54:11.370 --> 02:54:14.429
to 75 million, we weren't able to get that many more

02:54:14.440 --> 02:54:17.209
resources. One because I think, and you didn't say

02:54:17.218 --> 02:54:19.429
this, but I think that the resources were just more

02:54:19.440 --> 02:54:22.308
expensive because we, we uh moved that tool out of

02:54:22.319 --> 02:54:24.569
the emergency tool kit. So we're gonna have to pay

02:54:24.579 --> 02:54:29.120
more um to use those earlier. And then number two,

02:54:30.079 --> 02:54:32.569
the TDU load management program sort of cannibalize

02:54:32.579 --> 02:54:36.649
the es program at least for the summer. Um And we maybe

02:54:36.659 --> 02:54:39.099
the winter is still sculling up from the TDU load management

02:54:39.110 --> 02:54:41.349
perspective, but that's something we need. Keep in

02:54:41.360 --> 02:54:45.500
mind and there's one other reason why, you know, during

02:54:45.509 --> 02:54:49.489
the discussion about raising it as we also um increase

02:54:49.500 --> 02:54:53.950
the number of hours that we can deploy these resources

02:54:54.239 --> 02:54:57.179
It used to be 12 or what we actually called eight plus

02:54:57.190 --> 02:55:00.769
four. But the maximum deployment time during a contract

02:55:00.780 --> 02:55:05.329
period was, was 12 hours in all standard contract terms

02:55:05.519 --> 02:55:08.280
Now we moved to where we have up to 24 hours in

02:55:08.290 --> 02:55:11.229
the winter standard contract term and we've kept it

02:55:11.239 --> 02:55:15.019
12 hours, not an eight plus four, but a flat 12 for

02:55:15.030 --> 02:55:18.620
the other three. The, the spring, summer and fall standard

02:55:18.629 --> 02:55:21.459
contract terms are all 12. But winter, we've moved

02:55:21.468 --> 02:55:25.079
that to 24 because again, we've observed winter events

02:55:25.088 --> 02:55:27.409
seem to be much longer duration events than, than these

02:55:27.418 --> 02:55:31.549
summer events. Summers are two or three hours and you're

02:55:31.558 --> 02:55:34.860
out of it, max. Do you believe the cost will go up

02:55:34.870 --> 02:55:37.269
for this winter? We only, again, we only have one winner

02:55:37.280 --> 02:55:40.829
under our belt in terms of the enhanced deployment

02:55:40.838 --> 02:55:44.888
of s capability, the relax standard since the rule

02:55:44.899 --> 02:55:48.769
change, I believe that's right. You mean you mean when

02:55:48.780 --> 02:55:53.759
we went from a level one and two to prep it? Yeah

02:55:54.218 --> 02:55:57.290
Yeah. I think last winter was the first, was the first

02:55:57.299 --> 02:56:01.239
one. I think so. So everybody didn't know how often

02:56:01.250 --> 02:56:05.190
they would truly be deployed. Now, we're using it so

02:56:05.200 --> 02:56:08.989
they expect to be called on. Thus, higher values may

02:56:09.000 --> 02:56:14.579
be expected. Yes. Yes. Yes. But I still think it takes

02:56:14.588 --> 02:56:17.718
a while to grow the program too. I, I still think it'll

02:56:17.729 --> 02:56:22.409
grow actually, I think it'll grow with crypto loads

02:56:22.418 --> 02:56:25.690
I mean, if crypto loads can't find another service

02:56:25.700 --> 02:56:28.489
they're comfortable in. This may be one that they,

02:56:28.500 --> 02:56:32.509
they will still be wanting to participate in. But wouldn't

02:56:32.519 --> 02:56:37.718
they be price responsive anyway? Well, we, we don't

02:56:37.729 --> 02:56:44.450
currently, um for es we, we've allowed es to be price

02:56:44.459 --> 02:56:48.190
responsive ahead of a deployment event. But we've been

02:56:48.200 --> 02:56:52.179
very consistent in telling them though, if you do this

02:56:52.190 --> 02:56:55.250
if you do that and you do it very often, it not

02:56:55.259 --> 02:56:58.638
only it will impact your payment because of your availability

02:56:59.209 --> 02:57:02.040
but it could mess up. I was going to say another word

02:57:02.049 --> 02:57:05.440
mess up your baseline and you could have a difficult

02:57:05.450 --> 02:57:10.418
issue performing. Um And I'm actually a little concerned

02:57:10.429 --> 02:57:14.409
that I'm starting to see that. And so they're going

02:57:14.418 --> 02:57:17.709
to have to determine how much self deployment they're

02:57:17.718 --> 02:57:21.308
willing to, they, they can do and, and still meet the

02:57:21.319 --> 02:57:24.739
metrics for the service. Ok.

02:57:26.679 --> 02:57:30.179
So I would just one question. So, do you see any more

02:57:30.190 --> 02:57:32.370
low hanging fruit here for this winter,

02:57:35.620 --> 02:57:40.200
um, to expand this? No, because I, I mean, not, no

02:57:40.209 --> 02:57:43.530
I mean, unless, unless they've actually, I haven't

02:57:43.540 --> 02:57:47.040
seen yet, if I'm going to really see a much bigger

02:57:47.049 --> 02:57:50.239
bump than what I've already communicated to you, I

02:57:50.250 --> 02:57:53.530
would think a year has been enough for them to have

02:57:53.540 --> 02:57:57.638
gone out there and, and, and, and put their marketing

02:57:57.649 --> 02:58:01.040
teams out there and, and try to get additional capacity

02:58:01.418 --> 02:58:04.088
We'll see. But I it's just too, really, too early to

02:58:04.399 --> 02:58:08.769
to, I guess I just, my, my question is the really,

02:58:08.860 --> 02:58:09.888
you said that there were

02:58:11.909 --> 02:58:17.058
many other megawatts that were too expensive. So, um

02:58:17.509 --> 02:58:20.610
and the question that I have is what is that compared

02:58:20.620 --> 02:58:24.409
to, is it compared to just the earlier offers. Um It's

02:58:24.418 --> 02:58:28.129
not, it's not compared to a system outage or the high

02:58:28.138 --> 02:58:32.959
prices in the real time market. And that's kind of

02:58:32.968 --> 02:58:35.909
the question that I have is that in the future, is

02:58:35.918 --> 02:58:38.940
that a better comparison to be looking at? Because

02:58:39.250 --> 02:58:43.940
you may pay 5000. Well, you may pay, you know, mo most

02:58:43.950 --> 02:58:48.058
of the es uh it may be just say $100 a Megawatt

02:58:48.069 --> 02:58:52.229
hour. Um and you may have some that are $500 a Megawatt

02:58:52.239 --> 02:58:56.259
hour, but that's still cheaper than $5000 a Megawatt

02:58:56.280 --> 02:58:59.440
hour. That might happen in the real time market. So

02:58:59.450 --> 02:59:02.459
uh it's just uh you know, it's, it's math but it's

02:59:02.468 --> 02:59:04.899
uh it's a question of what you're comparing it to.

02:59:05.229 --> 02:59:08.218
It's, but it's a, it's not a pay as b it's a

02:59:08.229 --> 02:59:11.579
clearing price so that it may not seem like a very

02:59:11.588 --> 02:59:15.769
big increase in price, but the overall cost of the

02:59:15.780 --> 02:59:20.489
service will because it elevate all other bids. Awards

02:59:20.500 --> 02:59:25.329
will apply to every offer. You clear it. So its

02:59:27.129 --> 02:59:30.870
but we still, you see, I'm sorry, go ahead. I was just

02:59:30.879 --> 02:59:33.149
going to say just, it's still the comparison of the

02:59:33.159 --> 02:59:38.159
the alternative. That's the big question there. I'm

02:59:38.168 --> 02:59:42.370
sorry. Go on Mark. This is all 30 minute notice, right

02:59:43.819 --> 02:59:47.750
It's almost, well, it can be 30 10 but we have now

02:59:47.759 --> 02:59:52.290
seen for various reasons. They've almost all migrated

02:59:52.299 --> 02:59:57.338
to 30. I think this past procurement out of the 1000

02:59:57.370 --> 03:00:00.159
megawatts and we'll just call it typically less than

03:00:00.168 --> 03:00:03.418
50. It's actually around 26 or 27 megawatts is all

03:00:03.429 --> 03:00:05.690
we're seeing in 10. Now. That's very small. So it's

03:00:05.700 --> 03:00:09.329
almost all migrated. But we also, we procure it all

03:00:09.338 --> 03:00:14.769
Now, we, we deployed all now at the same time when

03:00:14.780 --> 03:00:17.750
it was an EE A, we used to do part of it

03:00:18.808 --> 03:00:22.940
part of it in one and, and, and 30 31 and E

03:00:23.120 --> 03:00:27.009
uh no, you know, and, and the 10 and two now, since

03:00:27.019 --> 03:00:30.019
we moved it all to pr C 3000, we deployed all at

03:00:30.030 --> 03:00:34.299
one in one instruction. So there's really the, the

03:00:34.308 --> 03:00:37.209
reasoning for having it separated as

03:00:39.349 --> 03:00:43.739
it only puts more, more um more, it makes it more difficult

03:00:43.750 --> 03:00:47.849
actually for the resources to meet compliance if you're

03:00:47.860 --> 03:00:51.209
staying 10. Um So why not move to 30? I mean, that's

03:00:51.218 --> 03:00:53.968
and I think that's what we're seeing. So tell

03:00:57.159 --> 03:01:01.659
any more questions? No. Ok. Thank you. Thank you. Next

03:01:01.668 --> 03:01:04.979
panel is transmission and distribution utilities and

03:01:04.989 --> 03:01:08.058
we have six companies. It will take about 30 minutes

03:01:08.069 --> 03:01:10.718
So, do you want to take a short break now or after

03:01:10.729 --> 03:01:12.479
that? I just wanna make sure

03:01:14.129 --> 03:01:18.540
you wanna, you wanna wait or take, I could use a break

03:01:18.700 --> 03:01:21.058
Um I can use, all right,

03:01:24.250 --> 03:01:27.110
let's look, recess for a short break and then um we'll

03:01:27.120 --> 03:01:30.168
we'll come back in about 10 minutes. Uh, we'll see

03:01:30.179 --> 03:01:33.429
you in, um, 11, 18,

03:01:41.989 --> 03:01:46.690
11 22 and we will resume our work session. I want to

03:01:46.700 --> 03:01:49.040
thank everyone for being here.

03:01:51.668 --> 03:01:56.418
So let's, let's get see back in the saddle. Ok. So

03:01:56.579 --> 03:01:59.209
I want to thank everybody for, uh, for participating

03:01:59.218 --> 03:02:01.440
in being here and for your comments and just remind

03:02:01.450 --> 03:02:05.299
folks that, um, if you have any kind of side conversations

03:02:05.308 --> 03:02:09.019
to please take them outside the room. So, um AA would

03:02:09.030 --> 03:02:12.500
you like to uh resume with? Section one? The topic

03:02:12.509 --> 03:02:15.739
is current demand response programs and load management

03:02:15.750 --> 03:02:18.968
and our transmission and distribution utilities and

03:02:18.979 --> 03:02:26.530
an invite TPTE encre CenterPoint, a Texas and T

03:02:29.379 --> 03:02:32.959
and I believe TT P A and TEC verbal only and the

03:02:32.968 --> 03:02:34.530
rest have some slides.

03:02:36.250 --> 03:02:39.629
OK. Taylor, you go first this time. Yes, thank you

03:02:39.808 --> 03:02:43.489
Uh Hi Taylor Ker from TPP again, as I mentioned, this

03:02:43.500 --> 03:02:46.379
is verbal only. Uh I do want to flag that a lot

03:02:46.388 --> 03:02:49.218
of our mo us do maintain some really robust demand

03:02:49.229 --> 03:02:52.549
response programs and it's not just the big ones here

03:02:52.610 --> 03:02:56.388
Uh A energy or CPS is Greenville with 16,000 m is a

03:02:56.399 --> 03:03:00.019
really good demand response program. Uh that said,

03:03:00.069 --> 03:03:02.950
you know, the continuing uh supply chain constraints

03:03:02.959 --> 03:03:06.009
from COVID are really hampering the efforts of of new

03:03:06.019 --> 03:03:08.558
AMI deployments. And so kind of what we got is what

03:03:08.569 --> 03:03:12.110
we got. But that said every mou maintains a really

03:03:12.120 --> 03:03:15.649
robust informal demand response program. And so when

03:03:15.659 --> 03:03:19.129
eco says uh we need help. That message is amplified

03:03:19.138 --> 03:03:23.319
not only by the mou but also City Hall, City Ems and

03:03:23.329 --> 03:03:26.968
so we will be there uh if needed. That's all. Thank

03:03:26.979 --> 03:03:27.168
you.

03:03:29.718 --> 03:03:33.819
Thank you. Uh Julia. Yes, great. Uh Good morning chair

03:03:33.829 --> 03:03:36.429
Jackson commissioners, Julia Harvey with Texas Electric

03:03:36.440 --> 03:03:39.500
Cooperative's. Uh happy to be here to talk about co

03:03:39.638 --> 03:03:44.569
op demand response. So regarding current co op D programs

03:03:44.579 --> 03:03:47.849
the thermostat load control is familiar territory for

03:03:47.860 --> 03:03:51.500
co ops. The majority of our more suburban members have

03:03:51.700 --> 03:03:54.629
those types of programs in place or have them at one

03:03:54.638 --> 03:03:58.349
point or are very close to deploying them. Those programs

03:03:58.360 --> 03:04:01.099
are typically designed around the summer because that's

03:04:01.110 --> 03:04:04.489
traditionally been the cost driver around high wholesale

03:04:04.575 --> 03:04:09.683
prices and four P cost allocation, we estimate the

03:04:09.704 --> 03:04:12.575
thermostat load control for co ops is probably around

03:04:12.584 --> 03:04:16.034
200 megawatts for the summer. Uh I just have a couple

03:04:16.043 --> 03:04:19.354
of observations about pivoting those programs to winter

03:04:19.364 --> 03:04:22.843
load control. Um from the couple of co ops that have

03:04:22.854 --> 03:04:26.274
kind of tried to do that. They've observed that after

03:04:26.284 --> 03:04:29.269
two hours, people just opt out because they start to

03:04:29.280 --> 03:04:34.468
get cold and uncomfortable. There can also be a a rebound

03:04:34.479 --> 03:04:36.849
effect where you just kind of shift the peak towards

03:04:36.860 --> 03:04:39.989
later in the day. It's something to be aware of. And

03:04:40.000 --> 03:04:42.069
then another challenge is that they don't always know

03:04:42.079 --> 03:04:44.940
if the premise has an electric heater or a gas heater

03:04:45.190 --> 03:04:47.149
And so if it's gas, it doesn't make a lot of sense

03:04:47.159 --> 03:04:49.620
to turn down the thermostat because it just turns down

03:04:49.629 --> 03:04:52.763
the gas heater, not the electric heater and just inconveniences

03:04:52.774 --> 03:04:55.304
people and doesn't save electricity, but some people

03:04:55.315 --> 03:04:58.263
still enroll in the program even so. So those are the

03:04:58.274 --> 03:05:02.065
challenges. So winter load control is not, not widespread

03:05:02.075 --> 03:05:06.304
in co op programs but, but as we speak and, and having

03:05:06.315 --> 03:05:08.084
learned a lot more the past couple of months, there

03:05:08.093 --> 03:05:11.843
are co ops evaluating more automated load control for

03:05:11.854 --> 03:05:15.638
this winter. And then finally, I just wanted to touch

03:05:15.649 --> 03:05:18.138
on conservation voltage reduction. You could maybe

03:05:18.149 --> 03:05:22.179
kind of consider that Dr R it's, that is designed around

03:05:22.190 --> 03:05:25.159
the four CP cost allocation, but it, it, it could be

03:05:25.168 --> 03:05:27.540
used in winter. And that's the expectation this this

03:05:27.549 --> 03:05:30.519
season. I don't know if there's, there's time or willingness

03:05:30.530 --> 03:05:33.259
for me to talk a little bit about the, the future potential

03:05:33.269 --> 03:05:37.338
of Co op Dr or if that's um maybe a different panel

03:05:37.668 --> 03:05:42.049
But yeah, let's finish. This sounds good. Thank you

03:05:42.058 --> 03:05:42.110
Encor.

03:05:45.540 --> 03:05:49.388
Good morning commissioners chair, I'm Gary Jones. I'm

03:05:49.399 --> 03:05:53.429
director of Energy Efficiency for encre um Acor will

03:05:53.440 --> 03:05:57.540
be offering uh both residential and commercial load

03:05:57.549 --> 03:06:00.588
management programs this winter. Uh The residential

03:06:00.599 --> 03:06:02.968
program is a new program. We're just kicking it off

03:06:02.979 --> 03:06:07.909
and currently recruiting uh reps and aggregation contractors

03:06:08.159 --> 03:06:10.659
So, if there are any reps here who are interested in

03:06:10.668 --> 03:06:14.110
the program, I'll make my spill. Um We're acquiring

03:06:14.120 --> 03:06:18.250
about uh 38 megawatts which equates to approximately

03:06:18.259 --> 03:06:22.429
38,000 residential customers. And we're going to use

03:06:22.440 --> 03:06:25.388
the same program designed for this program as we do

03:06:25.399 --> 03:06:29.929
for our residential summer program. Uh the commercial

03:06:29.940 --> 03:06:34.120
load management program uh for the winter, we have

03:06:34.129 --> 03:06:38.179
uh uh six participants representing 40 commercial customers

03:06:38.500 --> 03:06:42.338
Uh And we've enrolled about 36 megawatts. Uh The budget's

03:06:42.349 --> 03:06:46.500
fully subscribed at this point and uh we do have a

03:06:46.509 --> 03:06:51.440
wait list of other uh customers who are interested

03:06:51.450 --> 03:06:55.000
in, in participating but have not been allowed to yet

03:06:55.009 --> 03:06:58.769
So those are available. Uh Just generally our guidelines

03:06:58.780 --> 03:07:02.179
the programs are gonna run from December 1st until

03:07:02.190 --> 03:07:07.159
May 31st, 2024. Uh They are uh available 24 hours a

03:07:07.168 --> 03:07:11.569
day, seven days a week. Uh We only deploy our resources

03:07:11.579 --> 03:07:16.509
at an ee A level two and uh they're on a 30

03:07:16.519 --> 03:07:21.099
minute notification. Uh We, we do not allow them to

03:07:21.110 --> 03:07:25.329
enroll in ERCOT es and our programs. We, we work very

03:07:25.338 --> 03:07:29.918
closely with cot to validate that the uh the easy ideas

03:07:29.929 --> 03:07:33.259
only in one in one program or another. The default

03:07:33.269 --> 03:07:36.709
is if they're already in a uh A T er s, we

03:07:36.718 --> 03:07:39.739
don't allow them into the program and we, and we checked

03:07:39.750 --> 03:07:43.950
that on a monthly basis, critical care customers, as

03:07:43.959 --> 03:07:47.229
well as critical load. Customers are not allowed in

03:07:47.239 --> 03:07:52.429
our programs at this point. And then as a, to ensure

03:07:52.440 --> 03:07:55.159
that we are getting what we're we're paying for uh

03:07:55.168 --> 03:07:59.229
the customers must curtail at least 90% of their subscribed

03:07:59.239 --> 03:08:02.468
load during all events to be eligible for an incentive

03:08:02.479 --> 03:08:07.120
payment. And then lastly to determine our our savings

03:08:07.129 --> 03:08:10.099
we utilize the Texas Tech technical reference manual

03:08:11.360 --> 03:08:14.549
and that's all I have. Thank you, Center Point,

03:08:17.069 --> 03:08:20.069
good morning madam, chair and uh commissioners. My

03:08:20.079 --> 03:08:22.649
name is Elizabeth Brock and I'm Vice President of Energy

03:08:22.659 --> 03:08:25.450
Solutions for CenterPoint Energy. And I wanna thank

03:08:25.459 --> 03:08:27.489
you for giving us the opportunity to talk about our

03:08:27.500 --> 03:08:32.159
comprehensive energy uh efficiency portfolio that reduces

03:08:32.168 --> 03:08:35.040
peak demand and delivers energy savings and through

03:08:35.049 --> 03:08:39.370
a variety of programs and measures. Our programs are

03:08:39.379 --> 03:08:42.968
uh an effective tool to reduce peak demand during times

03:08:42.979 --> 03:08:47.019
of stress on the grid. Our current load offerings include

03:08:47.030 --> 03:08:51.019
a commercial load, residential and winter load management

03:08:51.030 --> 03:08:54.899
program. Historically, our load management programs

03:08:54.909 --> 03:08:58.009
have been focused on procuring capacity resources that

03:08:58.019 --> 03:09:01.440
can be deployed during summer uh peak periods from

03:09:01.450 --> 03:09:04.849
the hours of 1 to 7 and in the months of June

03:09:04.860 --> 03:09:08.588
July, September, I mean, August and September and that

03:09:08.599 --> 03:09:11.790
would be excluding weekends and holidays. However,

03:09:11.799 --> 03:09:15.079
we have a modified and expanded our tools to support

03:09:15.088 --> 03:09:17.790
the grid during emergencies that occur outside those

03:09:17.799 --> 03:09:21.870
summer peak periods. Looking forward, we will continue

03:09:21.879 --> 03:09:24.899
to advance our load management capabilities and expect

03:09:24.909 --> 03:09:28.009
that our programs will provide year round solutions

03:09:28.019 --> 03:09:33.530
for reliable and cost effective demand reduction. Our

03:09:33.540 --> 03:09:36.440
commercial and residential load management program

03:09:36.450 --> 03:09:39.819
programs have been long standing demand response offering

03:09:39.829 --> 03:09:43.429
within our energy efficiency program portfolio. These

03:09:43.440 --> 03:09:46.149
programs were originally designed to demand during

03:09:46.159 --> 03:09:49.500
uh summer peak times, as I mentioned earlier. And until

03:09:49.509 --> 03:09:53.049
recently, the company did not have a demand response

03:09:53.058 --> 03:09:56.718
tools during to be deployed on a 24 hour seven day

03:09:56.729 --> 03:10:01.269
a week basis or on the shoulder months of October and

03:10:01.280 --> 03:10:04.665
November. So to further expand our ability to support

03:10:04.674 --> 03:10:09.604
grid emergencies. This year, we began piloting modifications

03:10:09.614 --> 03:10:12.665
to our commercial and residential programs that will

03:10:12.674 --> 03:10:17.763
allow curtailment for 24 hours, seven days a week through

03:10:17.774 --> 03:10:19.924
the month of November of 2023.

03:10:21.929 --> 03:10:26.229
The program expansion pilot will just add another demand

03:10:26.239 --> 03:10:29.360
response capability to the grid during emergencies

03:10:29.370 --> 03:10:32.409
between the summer and winter peak periods.

03:10:34.138 --> 03:10:37.120
Our winter load management pilot program is designed

03:10:37.129 --> 03:10:40.399
to support grid emergencies during winter peak seasons

03:10:40.409 --> 03:10:43.838
providing reliable load curtailment that can be deployed

03:10:43.849 --> 03:10:47.610
24 hours a day and seven days a week as well. The

03:10:47.620 --> 03:10:51.259
program participants are incentivized to deliver measured

03:10:51.269 --> 03:10:56.009
and verifiable demand reduction. Participants included

03:10:56.019 --> 03:10:59.229
uh include customer and aggregators and the program

03:10:59.239 --> 03:11:02.808
is available to non-residential distribution customers

03:11:02.819 --> 03:11:06.808
as well as governmental educational and nonprofit transmission

03:11:06.819 --> 03:11:07.569
customers.

03:11:09.360 --> 03:11:11.860
CenterPoint is currently working to recruit and enroll

03:11:11.870 --> 03:11:16.179
participants in the 2023 2024 lo winter load management

03:11:16.190 --> 03:11:20.200
pilot program and the company is targeting 50 megawatts

03:11:20.280 --> 03:11:23.780
of curtailment load. The program will operate between

03:11:23.790 --> 03:11:28.979
the month of December 1st 2023 and February 29th of

03:11:28.989 --> 03:11:31.929
2024. Once again, thank you. I'm happy to answer any

03:11:31.940 --> 03:11:36.620
questions. Thank you. A EP Texas. Thanks, Jessica Seuss

03:11:36.629 --> 03:11:40.308
for a EP Texas. I just wanted to highlight some of

03:11:40.319 --> 03:11:43.549
the components of our winter load management program

03:11:43.780 --> 03:11:46.849
Uh This is a program we have that's available to non-residential

03:11:46.860 --> 03:11:49.888
customers. Uh They must be interruptible loads that

03:11:49.899 --> 03:11:53.700
are available 24 7 and must have an estimated savings

03:11:53.709 --> 03:11:57.569
of at least 100 kilowatts during the period that period

03:11:57.579 --> 03:12:01.370
runs from December through February. Uh We are currently

03:12:01.379 --> 03:12:05.379
enrolling participants in this. We're seeking 10 megawatts

03:12:05.388 --> 03:12:08.750
of participation. Uh And this is gonna be our third

03:12:08.759 --> 03:12:12.739
year in the program. Uh And we do verify these curtailments

03:12:12.750 --> 03:12:13.950
at the end of the period.

03:12:16.668 --> 03:12:20.569
Thank you the N MP. Good morning, Stacy Whitehurst

03:12:20.588 --> 03:12:24.110
with Texas New Mexico Power Company. We do have a commercial

03:12:24.120 --> 03:12:26.418
load management program this year. It will operate

03:12:26.429 --> 03:12:31.629
24 by seven between the uh December 1st 2023 and February

03:12:31.638 --> 03:12:36.829
29 2024. Obviously similar to what encre is triggered

03:12:36.838 --> 03:12:41.019
at an EE A two by ERCOT. Currently, we're trying to

03:12:41.030 --> 03:12:45.899
uh get 1.5 megawatts. Uh We opened up our applications

03:12:45.909 --> 03:12:50.009
yesterday and we've already received one Megawatt application

03:12:50.019 --> 03:12:52.968
to reserve. Obviously, there was some discussion about

03:12:52.979 --> 03:12:57.479
you know, canalizing the ES and what we do is we do

03:12:57.489 --> 03:13:00.280
not complete the application and enrollment process

03:13:00.418 --> 03:13:04.860
until actually we get verification from uh ERCOT on

03:13:04.870 --> 03:13:07.179
whether they are eligible to be signed up with us.

03:13:07.190 --> 03:13:10.558
So basically ERCOT scheme, the first ability to uh

03:13:10.569 --> 03:13:15.759
sign those customers up. It's a four hour deployment

03:13:15.769 --> 03:13:17.860
and we can call them up to five times

03:13:19.540 --> 03:13:23.299
throughout the period. And currently we do not have

03:13:23.308 --> 03:13:26.110
a residential demand response program, but we are looking

03:13:26.120 --> 03:13:27.110
to try to pilot one

03:13:29.829 --> 03:13:30.989
any questions

03:13:33.349 --> 03:13:36.329
and this is for, for the group, but especially at CenterPoint

03:13:36.620 --> 03:13:40.808
you use the term pilot program. I'm interested in the

03:13:40.819 --> 03:13:43.668
distinction between the pilot program. And then what

03:13:43.679 --> 03:13:50.549
is your existing dr constraints? Is your pilot deployed

03:13:50.558 --> 03:13:54.418
or dispatched only during eea conditions eea two conditions

03:13:54.429 --> 03:13:58.718
or, or when does that? When does that pilot begin to

03:13:58.729 --> 03:14:02.558
respond? Yes, during the eeee A two. OK.

03:14:04.549 --> 03:14:10.058
And what, what's the scale of that pilot? We are currently

03:14:10.069 --> 03:14:14.690
piloting um 50 megawatts and at the end of that pilot

03:14:14.700 --> 03:14:18.269
we'll evaluate whether uh we want to increase. Uh we

03:14:18.280 --> 03:14:20.450
we are looking forward to increasing, but we want to

03:14:20.459 --> 03:14:23.989
see what orchestrates are, right? And Stacy, what's

03:14:24.000 --> 03:14:26.468
what's your program at right now? In terms of scale

03:14:26.479 --> 03:14:30.429
size maximum is 1.5 for the winner. OK.

03:14:32.218 --> 03:14:40.819
Um And then encre yours was 50 it's 38 37 I think

03:14:40.829 --> 03:14:45.360
it's 37 for residential, 38 for residential, 37 for

03:14:45.370 --> 03:14:48.860
commercial A P. We are seeking 10 megawatts.

03:14:52.209 --> 03:14:54.759
Hey, Mark, you were writing feverishly over there.

03:14:54.769 --> 03:14:57.239
Did you know about these pilots and how they're being

03:14:57.250 --> 03:14:57.610
used?

03:15:03.379 --> 03:15:03.429
Ok.

03:15:04.950 --> 03:15:07.250
And, and we can get into more of that when we get

03:15:07.259 --> 03:15:10.750
into it, they'll answer questions on the RFP. I'm kind

03:15:10.759 --> 03:15:13.120
of wondering how these two things live together. I

03:15:13.129 --> 03:15:16.168
have a clarifying question for encre, as I was hearing

03:15:16.179 --> 03:15:19.729
all the information from different companies, the resources

03:15:20.138 --> 03:15:23.509
the program is typically run from December to February

03:15:23.588 --> 03:15:26.620
Your program runs from December to May, the end of

03:15:26.629 --> 03:15:30.838
May, can, can you touch on why your program is so long

03:15:30.849 --> 03:15:35.030
I'm just curious. Yes. The, the intent is to have two

03:15:35.040 --> 03:15:38.429
sets of programs, a winter set that runs from December

03:15:38.440 --> 03:15:42.168
to May and then a summer program that runs from, uh

03:15:42.179 --> 03:15:47.399
June 1st until November 30th. And so we'll be available

03:15:47.409 --> 03:15:51.030
365 days a year. Yeah, I'm just wondering like

03:15:52.700 --> 03:15:58.069
why till May. Great winter, the winter peak period

03:15:58.120 --> 03:16:02.200
begins in December through February and we conduct

03:16:02.209 --> 03:16:07.440
a test, um, to determine their, their contracted amount

03:16:07.940 --> 03:16:12.239
Uh, so we, we started in December and run that test

03:16:12.250 --> 03:16:14.940
and that determines their contract. We're running it

03:16:14.950 --> 03:16:18.190
through May or through the end of May so that we have

03:16:18.200 --> 03:16:21.709
complete coverage for the, uh, for the year. So even

03:16:21.718 --> 03:16:24.079
if we have an event in a shoulder month, we'll be able

03:16:24.088 --> 03:16:27.799
to deploy those resources shoulder. But this is a winter

03:16:27.808 --> 03:16:32.790
program. I'm just curious, we are, we're calling one

03:16:32.799 --> 03:16:36.168
program, a winter program and another a summer program

03:16:36.179 --> 03:16:41.280
and the summer runs from June 1st until November 30th

03:16:43.540 --> 03:16:49.159
for, for the Noy co ops and M are you restricted by

03:16:49.168 --> 03:16:52.500
eea conditions on where when your municipal utilities

03:16:52.509 --> 03:16:56.479
or cooperative's utilize Dr or what are the constraints

03:16:56.808 --> 03:16:59.399
Thank you, Commissioner. And you know, kind of as I

03:16:59.409 --> 03:17:01.940
alluded to, there is not really a large universe of

03:17:01.950 --> 03:17:07.829
of co op winter dr we, we do, you know there are

03:17:07.838 --> 03:17:10.929
systems of text alerts and other communications that

03:17:10.940 --> 03:17:14.849
happen and ERCOT issues, you know, its communications

03:17:15.120 --> 03:17:17.709
And since we know that ee a levels are changing, our

03:17:17.718 --> 03:17:21.280
members are now starting to change their communications

03:17:21.290 --> 03:17:25.179
to match that. But, but again, it's still kind of a

03:17:25.190 --> 03:17:28.329
new frontier for us and we're kind of looking at what

03:17:28.338 --> 03:17:30.759
our counterparts do and what's successful there and

03:17:30.769 --> 03:17:32.879
and what, you know, works in Houston might not work

03:17:32.888 --> 03:17:37.049
in a, in a really low density area but trying to understand

03:17:37.058 --> 03:17:39.308
if there's lessons learned there. Thank you. What about

03:17:39.360 --> 03:17:44.069
you, Taylor cps and a bigger systems doing this rather

03:17:44.079 --> 03:17:47.099
than Green Bull? Sure. So my understanding is that

03:17:47.829 --> 03:17:51.259
multiple nay have participated in the ES program, which

03:17:51.269 --> 03:17:54.200
does provide a limitation on, on when they can deploy

03:17:54.209 --> 03:17:57.588
that. Dr But um you know, we've got just basic kind

03:17:57.599 --> 03:18:00.299
of, you know, adjust your thermostat program. Cps right

03:18:00.308 --> 03:18:03.138
now is working on a winner specific product that we

03:18:03.149 --> 03:18:05.290
might not have this winter, but we hope to have really

03:18:05.299 --> 03:18:08.759
soon. And so we've got a good range of, of options

03:18:08.769 --> 03:18:12.388
for folks. Ok. And, and they're, they're, they're harnessing

03:18:12.399 --> 03:18:17.750
that to for both four CP uh as well as um as

03:18:17.759 --> 03:18:22.058
a uh load management hedge against price volatility

03:18:22.229 --> 03:18:24.379
It's both, you know, to benefit the utility in terms

03:18:24.388 --> 03:18:27.479
of four CP and S hedge. But also customers just want

03:18:27.489 --> 03:18:29.079
this, they want to have more control and they want

03:18:29.088 --> 03:18:32.209
to be able to help the grid sometimes. Ok. So bottom

03:18:32.218 --> 03:18:36.549
line is ERCOT may expect your dr outside of ee a conditions

03:18:36.950 --> 03:18:39.950
I think it is reasonable to think that MOUs would respond

03:18:39.959 --> 03:18:41.370
to those conditions. Ok.

03:18:45.780 --> 03:18:49.509
Any more questions? I guess I have one question. And

03:18:49.519 --> 03:18:54.360
that is, are all the dr programs funded through ECF

03:18:54.370 --> 03:18:56.790
just like energy efficiency programs or are these outside

03:18:56.799 --> 03:19:00.049
that this one is being funded through uh our energy

03:19:00.058 --> 03:19:02.989
efficiency cost recovery factory? Ok. Ok. Yes, all

03:19:03.000 --> 03:19:05.418
of ours are funded through ECRF. Ok.

03:19:07.940 --> 03:19:12.239
So that would tell you why the program goes 2012 months

03:19:12.558 --> 03:19:14.888
so they can be sure that they get their bonus.

03:19:16.769 --> 03:19:19.459
Actually, dr programs don't contribute that much to

03:19:19.468 --> 03:19:19.989
the bonus.

03:19:22.479 --> 03:19:23.440
I stand corrected.

03:19:26.638 --> 03:19:29.459
Thank you. No more questions. Thank you. Panel. I just

03:19:29.468 --> 03:19:31.968
want to ask, do you wanna take lunch time? We are very

03:19:31.979 --> 03:19:35.319
close to our lunch break we planned. Is that a good

03:19:35.329 --> 03:19:37.370
place? And we wanna, when do you wanna come back like

03:19:37.379 --> 03:19:39.110
12 30? Is that good?

03:19:44.450 --> 03:19:48.388
Um We'll, we'll go ahead and take a recess for lunch

03:19:48.399 --> 03:19:53.250
for 30 minutes. It's 11 40. And so we want people to

03:19:53.259 --> 03:19:57.200
come back and be ready to go at uh 12 10, which

03:19:57.209 --> 03:20:00.030
will be 30 minutes from now and we'll see you then

03:20:00.040 --> 03:20:00.549
Thank you

03:20:02.700 --> 03:20:06.239
12 26 and we will resume our resume our work session

03:20:06.250 --> 03:20:09.558
Um Parker, would you like to start with section two

03:20:09.569 --> 03:20:13.459
of your agenda? Potential additional resources? Sure

03:20:13.659 --> 03:20:17.179
The first subtopic is on the demand response and we

03:20:17.190 --> 03:20:20.200
are gonna just first invite residential demand response

03:20:20.209 --> 03:20:23.739
presenters, octopus, NRG and Tesla.

03:20:34.819 --> 03:20:38.259
Good afternoon commissioners. I'm Suzanne Burton Rajiv

03:20:38.280 --> 03:20:41.250
Shah was supposed to give this presentation for octopus

03:20:41.259 --> 03:20:45.000
energy today, but he had to leave at noon for an unavoidable

03:20:45.009 --> 03:20:48.459
conflict. So uh he's asked me to step in and pinch

03:20:48.468 --> 03:20:51.679
hit for him today. So uh with that, we'll get going

03:20:52.009 --> 03:20:55.700
uh appreciate the urgency of this situation. Uh While

03:20:55.709 --> 03:20:59.399
new generation takes years to build, unlocking existing

03:20:59.409 --> 03:21:03.319
resources only takes weeks or months. And demand response

03:21:03.329 --> 03:21:05.799
is key to unlocking the already built environment.

03:21:06.829 --> 03:21:09.159
We know that residential demand is the primary driver

03:21:09.168 --> 03:21:11.638
of winter peaks in Texas. And we believe residential

03:21:11.649 --> 03:21:15.120
dr is underutilized relative to its potential to relieve

03:21:15.129 --> 03:21:18.829
system constraints. In order to maximize residential

03:21:18.838 --> 03:21:21.588
and small commercial dr, we should be really thinking

03:21:21.599 --> 03:21:25.409
about uh out of the box alternatives al you know, alternatives

03:21:25.418 --> 03:21:29.269
to the traditional restrictive and prescriptive approaches

03:21:29.280 --> 03:21:32.879
that we've done in the past, we're envisioning a voluntary

03:21:32.888 --> 03:21:35.870
demand response program that meets customers where

03:21:35.879 --> 03:21:41.009
they are, where ERCOT currently issues calls for voluntary

03:21:41.019 --> 03:21:44.489
uncompensated demand reduction. This would provide

03:21:44.500 --> 03:21:47.349
customers with meaningful compensation for supporting

03:21:47.360 --> 03:21:51.929
grid reliability. Next slide, please gonna walk you

03:21:51.940 --> 03:21:55.709
through a program called the Demand Flexibility service

03:21:56.049 --> 03:21:59.638
that octopus energy participated in last winter and

03:21:59.649 --> 03:22:02.558
it was uh launched by the UK system operator national

03:22:02.569 --> 03:22:06.819
grid as a tool for managing system stress as the UK

03:22:06.829 --> 03:22:10.239
contended with potential fuel shortages uh due in large

03:22:10.250 --> 03:22:13.780
part to the ongoing conflict in Ukraine, the program

03:22:13.790 --> 03:22:16.329
was open to all suppliers and aggregators with the

03:22:16.338 --> 03:22:19.338
system operator paying for both residential and and

03:22:19.370 --> 03:22:24.250
demand reductions. It consisted of 10 test events during

03:22:24.259 --> 03:22:28.838
normal conditions and two live or real events if you

03:22:28.849 --> 03:22:32.129
will, which were triggered when insufficient upward

03:22:32.138 --> 03:22:35.808
flexibility was foreseen at the day ahead stage. And

03:22:35.819 --> 03:22:38.989
the system operator believed that the in inadequacy

03:22:39.000 --> 03:22:41.838
could not be solved by existing services and market

03:22:41.849 --> 03:22:45.429
incentives. Providers were paid a guaranteed acceptance

03:22:45.440 --> 03:22:52.418
price of £3 per kilowatt hour. That's 3 64 in um US

03:22:52.429 --> 03:22:56.979
dollars uh during the test events and they submitted

03:22:56.989 --> 03:23:02.009
competitive bids for the live events. So here's how

03:23:02.019 --> 03:23:05.329
this worked just in broad strokes. National grid solicited

03:23:05.338 --> 03:23:08.979
bids in the day ahead from providers. Providers would

03:23:08.989 --> 03:23:12.489
then submit bids. National grid notifies the providers

03:23:12.500 --> 03:23:15.509
if their bid is successful based on marginal clearing

03:23:15.519 --> 03:23:19.849
price providers ask customers to reduce energy use

03:23:19.860 --> 03:23:23.509
and customers opt in providers would then send the

03:23:23.519 --> 03:23:26.629
results to national grid with demand flexibility measured

03:23:26.638 --> 03:23:30.668
as the difference between actual metered usage data

03:23:30.679 --> 03:23:33.700
relative to the customer's baseline average usage.

03:23:33.909 --> 03:23:36.888
So this is worth emphasizing this is paid for only

03:23:36.899 --> 03:23:40.250
the performance that's delivered. Next slide please

03:23:41.588 --> 03:23:46.280
across the 12 DFS hours. The system operator called

03:23:46.290 --> 03:23:51.959
during the winter season, octopus was able to uh have

03:23:51.968 --> 03:23:57.209
700,000 of their 1.5 million smart meter UK. Customers

03:23:57.218 --> 03:24:01.929
signed up shifting 1.8 gigawatt hours of demand representing

03:24:01.940 --> 03:24:06.459
56% of the 3.3 gigawatt hours of demand reduction across

03:24:06.468 --> 03:24:11.679
the UK. Next slide, here's a view of demand response

03:24:11.690 --> 03:24:14.259
that occurred in each of the 12 events. Now this is

03:24:14.269 --> 03:24:18.329
just octopus customers. So total reduction across all

03:24:18.338 --> 03:24:21.620
the providers was roughly double what's depicted here

03:24:21.819 --> 03:24:26.099
Purple bars, the dark purple uh are test events during

03:24:26.110 --> 03:24:29.808
normal conditions and the pink bars are live events

03:24:29.819 --> 03:24:33.718
to respond to actual system stress. Next slide.

03:24:36.049 --> 03:24:40.588
So zooming in on the January 23rd event octopus customers

03:24:40.599 --> 03:24:46.069
provided 188 megawatts of manual dr. Next slide,

03:24:47.610 --> 03:24:50.138
as you can see here, the majority of our customers

03:24:50.149 --> 03:24:53.409
who signed up for the program ended up participating

03:24:53.418 --> 03:24:56.269
in these events and participation remained for the

03:24:56.280 --> 03:25:02.069
most part consistent. Next slide, octopus experimented

03:25:02.079 --> 03:25:04.989
with the timing of notice to customers in addition

03:25:05.000 --> 03:25:08.610
to the form of the notice. So email or text, for example

03:25:08.849 --> 03:25:12.459
with relatively small drop off and participation up

03:25:12.468 --> 03:25:15.829
until about two hours before the event. One of the

03:25:15.838 --> 03:25:19.870
next slide please. One of the key learnings from the

03:25:19.879 --> 03:25:22.218
first year of the program is that the vast majority

03:25:22.229 --> 03:25:25.450
of our customers want to continue participating. They

03:25:25.459 --> 03:25:29.019
have not experienced demand response fatigue. And this

03:25:29.030 --> 03:25:32.239
winter national grid is expanding the program including

03:25:32.250 --> 03:25:35.388
live events that will occur over 3 to 4 hour windows

03:25:35.399 --> 03:25:38.159
with, with providers able to bid into different settlement

03:25:38.168 --> 03:25:42.849
periods across those hours. So, uh, Commissioner McAdams

03:25:42.860 --> 03:25:45.769
this gets to your comment earlier about, you know,

03:25:45.780 --> 03:25:48.899
how in ERCOT, we've got the voluntary conservation

03:25:48.909 --> 03:25:52.959
notices that maybe, you know, aren't, maybe people

03:25:52.968 --> 03:25:55.299
getting a little bit tired of that. But in this case

03:25:55.308 --> 03:25:58.479
these customers were getting paid a pretty good amount

03:25:58.489 --> 03:26:02.838
of about anywhere from 5 to $10 for an event. And so

03:26:02.849 --> 03:26:08.049
up to £100 or about 100 and $20 over the program, how

03:26:08.058 --> 03:26:11.879
many uh total uh premises were involved in the 188

03:26:11.888 --> 03:26:15.759
megawatts? Uh I don't know the answer to that question

03:26:15.769 --> 03:26:18.950
but we can get back to you on that. Uh So next

03:26:18.959 --> 03:26:24.229
slide, please. So how this might work um in ERCOT.

03:26:24.290 --> 03:26:28.649
Uh First of all, I wanted to mention that uh er octopus

03:26:28.659 --> 03:26:32.349
in and of itself averaged 177 megawatts during the

03:26:32.360 --> 03:26:37.808
live events uh from its 1.4 mil million smart metered

03:26:37.819 --> 03:26:40.579
customers. So that gets to your question a little bit

03:26:41.079 --> 03:26:46.579
uh with 13 point sorry, 17.3 smart meters currently

03:26:46.588 --> 03:26:50.239
in the UK. This amounted to 2.1 gigawatts of potential

03:26:50.250 --> 03:26:54.679
dr at a cost less than 25% of what the system operator

03:26:54.690 --> 03:26:58.280
paid to dispatch the last resort thermal units. So

03:26:58.290 --> 03:27:02.149
what this could look like in ERCOT, uh octopus's rough

03:27:02.159 --> 03:27:05.950
estimate is that this represents approximately 4.4

03:27:05.959 --> 03:27:09.870
gigawatts of potential residential demand response

03:27:10.040 --> 03:27:13.780
While ERCOT has fewer residential meters than the UK

03:27:14.190 --> 03:27:17.149
the average Texas household consumes more than five

03:27:17.159 --> 03:27:20.989
times more electricity than the average UK household

03:27:21.799 --> 03:27:26.739
We could tailor the UK approach to ERCOT where LSES

03:27:26.750 --> 03:27:30.729
are paid for actual demand reduction post event at

03:27:30.739 --> 03:27:34.418
the outset. We propose that there not be penalties

03:27:34.429 --> 03:27:39.099
for over or underperformance. LSES first need data

03:27:39.110 --> 03:27:41.780
to understand participation levels and optimize the

03:27:41.790 --> 03:27:45.679
messaging and the timing of customer notices. You could

03:27:45.690 --> 03:27:48.489
run some tests during normal conditions providing a

03:27:48.500 --> 03:27:51.179
guaranteed acceptance price as they did in the UK.

03:27:51.799 --> 03:27:55.200
And uh we propose that live events would be triggered

03:27:55.209 --> 03:27:58.338
when the system reaches some operating reserve threshold

03:27:58.579 --> 03:28:02.429
which could be somewhere between deployment of ES and

03:28:02.440 --> 03:28:06.709
ee a one conditions. So what's presented here today

03:28:06.968 --> 03:28:11.110
Uh hopefully uh inspires some thinking uh about what

03:28:11.120 --> 03:28:13.569
could be done to deal with the situation at hand this

03:28:13.579 --> 03:28:17.440
winter but with the state's continuing and seemingly

03:28:17.450 --> 03:28:21.030
limitless growth, uh octopus looks forward to having

03:28:21.040 --> 03:28:23.769
conversations about additional ideas for unlocking

03:28:23.780 --> 03:28:27.429
the untapped potential for flexible loads that could

03:28:27.440 --> 03:28:30.239
be implemented with an additional year or two of lead

03:28:30.250 --> 03:28:34.500
time that concludes my remarks. Thank you, Suzanne

03:28:34.509 --> 03:28:35.069
and RG.

03:28:36.709 --> 03:28:38.899
Good afternoon commissioners. My name, my name is Christina

03:28:38.909 --> 03:28:41.229
Rollins. I'm Assistant General Counsel of Regulatory

03:28:41.239 --> 03:28:43.649
Affairs for NRG. And thank you for inviting us to have

03:28:43.659 --> 03:28:46.610
comments. Today. The NRG family of retail electric

03:28:46.620 --> 03:28:50.058
providers are prepared for the winter prior to and

03:28:50.069 --> 03:28:51.879
throughout the winter, we'll be communicating with

03:28:51.888 --> 03:28:54.549
our customers about the possibility of extreme weather

03:28:54.558 --> 03:28:57.370
events and how those events can increase their consumption

03:28:57.519 --> 03:29:00.569
and impact their electric bill. And it's on that issue

03:29:00.579 --> 03:29:03.718
where demand response becomes very relevant and very

03:29:03.729 --> 03:29:06.370
important. And we talk about demand response. We're

03:29:06.379 --> 03:29:09.190
really talking about a form of virtual power plants

03:29:09.200 --> 03:29:12.088
because virtual power plants are really any technology

03:29:12.209 --> 03:29:16.349
that reduces demand or produces energy on the distribution

03:29:16.360 --> 03:29:18.849
system that can reduce a customer's consumption from

03:29:18.860 --> 03:29:22.530
the grid on demand and so on demand side management

03:29:22.540 --> 03:29:24.769
For example, that would be like a thermostat that you

03:29:24.780 --> 03:29:27.530
could adjust and that would reduce the customer's consumption

03:29:27.540 --> 03:29:31.540
from the grid on the distributed energy resource side

03:29:31.549 --> 03:29:34.290
that would be like a battery or in that same demand

03:29:34.299 --> 03:29:37.388
response event, the customer could consume energy from

03:29:37.399 --> 03:29:39.979
the battery and kind of ride out the event without

03:29:39.989 --> 03:29:41.909
even feeling that it had happened. And so they wouldn't

03:29:41.918 --> 03:29:45.299
really be changing their energy usage at home. So both

03:29:45.308 --> 03:29:48.290
of those are things that um retail electric providers

03:29:48.299 --> 03:29:52.338
can use as tools to have a good demand response program

03:29:52.679 --> 03:29:56.659
And retailers are motivated to use demand response

03:29:56.668 --> 03:30:00.290
this winter and there are many reasons for that. But

03:30:00.299 --> 03:30:03.418
you know, for example, for avoidance of exposure to

03:30:03.429 --> 03:30:07.259
real time energy pricing when it is very cold outside

03:30:07.269 --> 03:30:11.329
energy consumption increases. And potentially if that

03:30:11.338 --> 03:30:13.909
consumption increases to a point that was not necessarily

03:30:13.918 --> 03:30:16.659
anticipated, you could expose the rep to real time

03:30:16.668 --> 03:30:19.569
energy pricing as well. And so you would want to decrease

03:30:19.579 --> 03:30:22.129
your customer's consumption to minimize the exposure

03:30:22.138 --> 03:30:26.259
to that pricing. Also because ancillary service costs

03:30:26.269 --> 03:30:29.269
are allocated to load serving entities on a load ratio

03:30:29.280 --> 03:30:32.450
share basis, you do have a motivation to decrease your

03:30:32.459 --> 03:30:35.209
load ratio share to decrease your exposure to those

03:30:35.218 --> 03:30:35.829
costs.

03:30:37.338 --> 03:30:41.599
And as far as demand response at NRG goes, um we have

03:30:41.610 --> 03:30:44.399
robust demand response programs that enable customers

03:30:44.409 --> 03:30:48.819
to receive a financial incentive for agreeing to adjust

03:30:48.829 --> 03:30:52.888
their demand when called upon. Um This reduced consumption

03:30:52.899 --> 03:30:56.000
also helps lower their bills as well. And so on the

03:30:56.009 --> 03:30:59.459
residential side, we have programs like reliance degrees

03:30:59.468 --> 03:31:01.690
of difference program which has been around for over

03:31:01.700 --> 03:31:05.079
a decade. Green mountains ready set, relax program

03:31:05.138 --> 03:31:08.190
and direct energies reduce your use program. These

03:31:08.200 --> 03:31:10.959
are programs that we can use year-round to be able

03:31:10.968 --> 03:31:14.418
to reduce demand when needed. On the larger commercial

03:31:14.429 --> 03:31:17.120
side, we have a program called the Responsive Economic

03:31:17.129 --> 03:31:20.899
Dispatch or red program, which is for larger customers

03:31:20.909 --> 03:31:24.280
Currently, that's mainly a summer only program which

03:31:24.290 --> 03:31:29.440
runs from June to September. And this kind of relates

03:31:29.450 --> 03:31:32.829
to the ERCOT RFP that was recently issued. Um You know

03:31:32.838 --> 03:31:36.780
NRG is continuing to evaluate the dor opportunities

03:31:37.019 --> 03:31:40.819
that are available in ERCOT S request for 3000 megawatts

03:31:40.829 --> 03:31:44.209
of capacity this summer. They have clarified this week

03:31:44.218 --> 03:31:48.049
that if a customer participated in a rep or third party

03:31:48.058 --> 03:31:50.718
demand response program within the last two years,

03:31:50.929 --> 03:31:53.530
they would be ineligible to participate. So that would

03:31:53.540 --> 03:31:56.479
render things that are like a summer only demand response

03:31:56.489 --> 03:31:59.099
program like that red program I just discussed and

03:31:59.110 --> 03:32:02.049
eligible to participate. Um And with that, I would

03:32:02.058 --> 03:32:04.989
just like to say that energy reps stand ready to help

03:32:05.000 --> 03:32:07.588
customers ERCOT and the commission to ensure we have

03:32:07.599 --> 03:32:12.370
a successful winter. Thank you. Thank you, Tesla. Uh

03:32:12.379 --> 03:32:14.418
Good afternoon commissioners, appreciate the time.

03:32:14.429 --> 03:32:16.909
Uh Greg Turner representing Tesla Energy, a retail

03:32:16.918 --> 03:32:19.700
electric provider in ERCOT and an aggregator of demand

03:32:19.709 --> 03:32:22.899
response programs across the globe. Um considering

03:32:22.909 --> 03:32:25.450
the magnitude of ERCOT s request and the timing between

03:32:25.459 --> 03:32:28.088
now and the winter, we offer these comments to try

03:32:28.099 --> 03:32:32.200
and guarantee a maximum achievable outcome in terms

03:32:32.209 --> 03:32:34.739
of incremental demand response as well as a competitive

03:32:34.750 --> 03:32:38.168
outcome because ERCOT demand response programs thus

03:32:38.179 --> 03:32:41.239
far are very unique and successful. Uh although they're

03:32:41.250 --> 03:32:44.280
dominated on a capacity weighted weighted basis by

03:32:44.290 --> 03:32:47.440
commercial industrial segments, residential consumers

03:32:47.450 --> 03:32:50.058
do participate in a meaningful way, particularly in

03:32:50.069 --> 03:32:52.138
the weather sensitive BRS programs that have been mentioned

03:32:52.149 --> 03:32:54.849
earlier. Though those capabilities are distinct and

03:32:54.860 --> 03:32:58.790
different during the winter. Uh Both as Julia Harvey

03:32:58.799 --> 03:33:02.030
mentioned earlier because some Texas electric consumers

03:33:02.079 --> 03:33:06.329
use gas for heat. And uh the tolerance for interrupting

03:33:06.338 --> 03:33:08.269
a thermostat is much different during the winter than

03:33:08.280 --> 03:33:11.610
it is during the summer. Our customers who own power

03:33:11.620 --> 03:33:15.000
walls and electric vehicles or both have the capacity

03:33:15.009 --> 03:33:18.269
when properly noticed and incentivized to deliver incremental

03:33:18.280 --> 03:33:22.479
demand response to the ERCOT system. And this can continue

03:33:22.489 --> 03:33:26.168
in times of extreme weather in many instances because

03:33:26.179 --> 03:33:28.459
a battery enables powering a home in a way that doesn't

03:33:28.468 --> 03:33:32.399
interrupt their actual consumption. As a parent at

03:33:32.409 --> 03:33:35.088
the meter, of course, it would be interrupted. But

03:33:35.099 --> 03:33:37.709
within the premise, there would be less or no discomfort

03:33:38.780 --> 03:33:41.599
and as our device count grows so too does our capability

03:33:41.610 --> 03:33:44.399
to provide incremental demand response to ERCOT? We

03:33:44.409 --> 03:33:47.519
estimate that distributed battery electric storage

03:33:47.530 --> 03:33:51.159
systems as they exist today on ERCOT could deliver

03:33:51.168 --> 03:33:54.509
up to 700 megawatts of incremental demand response

03:33:54.519 --> 03:33:56.599
not realized. Now during the winter

03:33:58.149 --> 03:34:00.239
and we've demonstrated by enlisting our customers in

03:34:00.250 --> 03:34:02.808
various demand response programs elsewhere in North

03:34:02.819 --> 03:34:05.069
America and across the globe, the technical capability

03:34:05.079 --> 03:34:08.370
to provide fast responding reserves less than a second

03:34:08.379 --> 03:34:12.239
response time from a growing and enthusiastic population

03:34:12.250 --> 03:34:13.329
of device owners.

03:34:14.860 --> 03:34:17.918
And when we develop a program or solicit participation

03:34:17.929 --> 03:34:20.709
in a program, we strive to provide an intuitive incentive

03:34:20.718 --> 03:34:24.450
to our customers. We don't seek out programs on behalf

03:34:24.459 --> 03:34:26.718
of our customers unless we can make it easy to understand

03:34:26.729 --> 03:34:30.379
describe and inform in real time how their device will

03:34:30.388 --> 03:34:33.849
contribute to forestalling an emergency event. And

03:34:33.860 --> 03:34:36.989
this is very important to Tesla. We believe it's crucial

03:34:37.000 --> 03:34:39.418
to instilling and maintaining a trustworthy relationship

03:34:39.429 --> 03:34:42.250
with our customers. The experience thereafter allows

03:34:42.259 --> 03:34:44.290
the customer to utilize their devices in a manner that's

03:34:44.299 --> 03:34:46.899
consistent with their primary intentions for the device

03:34:46.918 --> 03:34:50.079
Sometimes it's resiliency, sometimes it's transportation

03:34:50.239 --> 03:34:53.370
sometimes it's both. But by participating in these

03:34:53.379 --> 03:34:55.388
programs, they have an opportunity to lower the cost

03:34:55.399 --> 03:34:59.079
of ownership of that device and help out the grid and

03:34:59.088 --> 03:35:02.588
their fellow Texans. I'll now focus on my first three

03:35:02.599 --> 03:35:07.849
points to try and expand what we can deliver uh in

03:35:07.860 --> 03:35:10.349
light of the very tight timeline between now and the

03:35:10.360 --> 03:35:14.120
winter. And I'll begin by saying that residential consumers

03:35:14.129 --> 03:35:17.218
unlike commercial and industrial consumers can seldom

03:35:17.229 --> 03:35:20.780
if ever forecast on a forward looking basis how they

03:35:20.790 --> 03:35:24.329
intend to use their Tesla devices. Correspondingly

03:35:24.338 --> 03:35:26.780
as their aggregator of demand response, it's very difficult

03:35:26.790 --> 03:35:29.729
to submit a forward looking estimate of our capability

03:35:29.739 --> 03:35:34.429
under various grid emergencies or scenarios. What's

03:35:34.440 --> 03:35:37.909
more if Tesla is the aggregator representing that offer

03:35:37.918 --> 03:35:40.649
on behalf of our customers, we must assume the most

03:35:40.659 --> 03:35:44.329
conservative availability of our capacity under various

03:35:44.338 --> 03:35:47.709
circumstances. We will undoubtedly leave capability

03:35:47.739 --> 03:35:51.500
on the table. So said another way, if we forecast a

03:35:51.509 --> 03:35:54.159
Uri and we offer what we think we can have in a

03:35:54.179 --> 03:35:58.379
Urry, we may have left megawatts unavailable for a

03:35:58.388 --> 03:36:00.870
winter storm Elliott or something of lesser magnitude

03:36:03.388 --> 03:36:06.209
what's more we want to protect our customer base from

03:36:06.218 --> 03:36:09.888
penalties. These customers, residential customers don't

03:36:09.899 --> 03:36:12.569
buy a device with the intent of offering into a market

03:36:12.579 --> 03:36:16.079
program. They, they buy a device for their own purposes

03:36:16.860 --> 03:36:20.058
And when we try to enlist their support in these programs

03:36:20.290 --> 03:36:23.468
it is very difficult to communicate that we want their

03:36:23.479 --> 03:36:26.780
help as a Texas Electric consumer to help assist the

03:36:26.790 --> 03:36:29.500
grid in the case of emergency. But if you can't, there

03:36:29.509 --> 03:36:30.399
might be a penalty,

03:36:32.058 --> 03:36:35.918
successful residential demand response programs compensate

03:36:35.929 --> 03:36:38.399
consumers based on what they can deliver in real time

03:36:39.718 --> 03:36:42.659
Ideally, this would be a program where when called

03:36:42.668 --> 03:36:45.899
upon we get compensated precisely for what we provide

03:36:45.909 --> 03:36:48.599
with no penalties. And there are examples of these

03:36:48.610 --> 03:36:51.959
programs that I'll explore for your information, but

03:36:51.968 --> 03:36:56.649
we realize that without a defined quantity, ERCOT won't

03:36:56.659 --> 03:36:59.379
have any more comfort going into a winter preparing

03:36:59.388 --> 03:37:03.549
for an event. Nonetheless, we are certain that programs

03:37:03.558 --> 03:37:06.269
that reward customers in a pay for performance, excuse

03:37:06.280 --> 03:37:09.799
me, pay for performance mechanism will encourage them

03:37:09.808 --> 03:37:12.519
to participate with all the cap capability they have

03:37:12.530 --> 03:37:16.668
available at the time of the event. So consider uh

03:37:16.679 --> 03:37:20.299
the emergency load reduction program on the west coast

03:37:20.308 --> 03:37:22.790
I've heard, I've heard that uh California programs

03:37:22.799 --> 03:37:24.489
don't resonate. Well, in Texas

03:37:26.079 --> 03:37:29.088
known as er P or emergency load reduction program,

03:37:29.620 --> 03:37:32.940
each participating customer earns $2 per kilowatt hour

03:37:32.950 --> 03:37:35.718
for each incremental kilowatt hour delivered during

03:37:35.729 --> 03:37:38.870
a declared emergency. And that energy is truly incremental

03:37:38.879 --> 03:37:41.729
The system. In many instances, our devices are forbid

03:37:41.739 --> 03:37:44.450
from grid charging. They're solar charged and they're

03:37:44.459 --> 03:37:47.500
compensated for the energy they delivered during that

03:37:47.509 --> 03:37:48.129
emergency,

03:37:49.679 --> 03:37:52.319
Tesla customers receive, receive immediate notice that

03:37:52.329 --> 03:37:55.308
their devices are being utilized for that grid event

03:37:55.319 --> 03:37:59.200
and in discharging and they get a very quick uh estimate

03:37:59.209 --> 03:38:02.780
if not actual value created for that customer. And

03:38:02.790 --> 03:38:06.308
the grid events are constrained to time periods and

03:38:06.319 --> 03:38:08.849
months. Much like the program devi designed in the

03:38:08.860 --> 03:38:13.099
RP uh though targeted at the summer months in California

03:38:13.110 --> 03:38:15.659
as well as some of the shoulder months, May. And October

03:38:18.799 --> 03:38:21.780
second, successful residential emergency demand response

03:38:21.790 --> 03:38:24.989
programs enroll customers would demand response incentives

03:38:25.000 --> 03:38:28.088
that are established before enrollment is opened. It

03:38:28.099 --> 03:38:33.440
is very difficult to solicit participation with a maybe

03:38:33.450 --> 03:38:38.079
offer. So that another way if we use our channels in

03:38:38.088 --> 03:38:41.069
most instances, it's through our Tesla App to communicate

03:38:41.079 --> 03:38:43.360
with our customers and ask them to participate in one

03:38:43.370 --> 03:38:47.229
of these programs, we would be handicapping what the

03:38:47.239 --> 03:38:50.099
value would be as part of our response to the RFP.

03:38:50.659 --> 03:38:53.769
And our solicitation to our customer would be sign

03:38:53.780 --> 03:38:57.790
up endorse that we're able to represent your capability

03:38:57.799 --> 03:39:00.959
in an emergency event. And if we are selected, we will

03:39:00.968 --> 03:39:04.629
let you know. So those caveats tend to go against the

03:39:04.638 --> 03:39:07.379
principles of keeping it simple, easy to understand

03:39:07.388 --> 03:39:11.159
transparent. Uh By comparison in California, those

03:39:11.168 --> 03:39:13.468
enrolled customers who participate, get compensated

03:39:13.479 --> 03:39:17.329
for the incremental uh energy that they delivered during

03:39:17.338 --> 03:39:20.040
an emergency which I might also add is an alternative

03:39:20.049 --> 03:39:22.870
to a costly standby payment that may never be used

03:39:23.229 --> 03:39:25.668
in the case of a mild winter or a mild winter with

03:39:25.679 --> 03:39:29.799
no emergency events. We have a similar nascent program

03:39:29.808 --> 03:39:33.149
in Puerto Rico where Luma, the local utility established

03:39:33.159 --> 03:39:35.989
the terms conditions and value paid to the consumers

03:39:36.138 --> 03:39:39.290
within their service territory. And thereafter, aggregators

03:39:39.299 --> 03:39:41.968
can present that offer so that a customer may consider

03:39:41.979 --> 03:39:45.870
the value that they receive from participation as an

03:39:45.879 --> 03:39:49.468
alternative to purchasing that device for their original

03:39:49.479 --> 03:39:52.899
investment thesis. And I might add, if you're not familiar

03:39:52.909 --> 03:39:56.040
with the operations of the Puerto Rico grid. Uh rolling

03:39:56.049 --> 03:39:58.530
outages are very frequent if not daily. In the summer

03:39:58.540 --> 03:40:01.799
months, we have the highest concentration of devices

03:40:02.079 --> 03:40:05.769
in the world in Puerto Rico 400 megawatts on a 2800

03:40:05.780 --> 03:40:10.759
Megawatt system. So said another way uh we could unilaterally

03:40:10.769 --> 03:40:15.099
forestall system of emergencies with the capacity once

03:40:15.110 --> 03:40:18.110
enrolled and we're in the process of doing so, but

03:40:18.120 --> 03:40:20.588
that customer has to know what the offer is, how they

03:40:20.599 --> 03:40:23.799
must participate. And more importantly know what benefits

03:40:23.808 --> 03:40:26.849
they'll receive. So they can weigh that incentive against

03:40:26.860 --> 03:40:30.360
their own value of resiliency as an alternative to

03:40:30.370 --> 03:40:31.940
participating in a great program

03:40:37.620 --> 03:40:41.149
just to reiterate. And this is my final point. Successful

03:40:41.159 --> 03:40:45.138
demand response programs compensate participants only

03:40:45.149 --> 03:40:48.120
for what they deliver in a test or an actual emergency

03:40:48.479 --> 03:40:51.659
This not only guarantees maximum available participation

03:40:51.668 --> 03:40:55.540
at the time of the event. But it also makes unnecessary

03:40:55.549 --> 03:40:59.319
clawback penalties or burdensome tariffs irrelevant

03:41:00.250 --> 03:41:03.679
They're neither necessary or used. The customer receives

03:41:03.690 --> 03:41:06.968
a fixed dollar per kilowatt hour payment for everything

03:41:06.979 --> 03:41:11.009
they deliver to the system and compensating customers

03:41:11.019 --> 03:41:13.379
at the value of lost load has been the approach taken

03:41:13.388 --> 03:41:16.679
in California and elsewhere across the world. We offer

03:41:16.690 --> 03:41:18.799
that as an example that could be considered in ERCOT

03:41:18.808 --> 03:41:23.209
as well. And W is Ball in California. When they designed

03:41:23.218 --> 03:41:25.950
the Elrp program, it was $2 per kilowatt hour.

03:41:32.808 --> 03:41:35.259
But we realize the ERCOT stakeholder community has

03:41:35.269 --> 03:41:38.099
limited time to act before the beginning of winter

03:41:38.290 --> 03:41:40.610
And demand response providers have even less time to

03:41:40.620 --> 03:41:43.479
solicit participation and role and design a well functioning

03:41:43.489 --> 03:41:47.190
program. It's for this reason, we encourage that we

03:41:47.200 --> 03:41:51.418
use this RP opportunity as a singular data point to

03:41:51.429 --> 03:41:55.110
expand and inform future programs. But we are still

03:41:55.120 --> 03:41:58.500
ardent supporters of the AD er program that creates

03:41:58.509 --> 03:42:02.250
a pay for performance experience that's market driven

03:42:02.479 --> 03:42:05.019
and purchased in quantities that can be adjusted on

03:42:05.030 --> 03:42:08.489
a day ahead basis. That makes it easy and intuitive

03:42:08.500 --> 03:42:11.479
for aggregators and customers to ascertain what their

03:42:11.489 --> 03:42:14.468
true capabilities are today for tomorrow rather than

03:42:14.479 --> 03:42:18.360
today for the next 90 days, given the unpredictability

03:42:18.370 --> 03:42:20.549
and potential severity of a Texas winter.

03:42:23.009 --> 03:42:27.829
So, uh in closing, you know, we encourage this opportunity

03:42:27.838 --> 03:42:31.849
to be a fruitful one and we will certainly do everything

03:42:31.860 --> 03:42:35.159
we can to develop a program. Despite the constraints

03:42:35.168 --> 03:42:37.649
I've illustrated it is going to be very difficult and

03:42:37.659 --> 03:42:39.838
we've thought long and hard since this has been issued

03:42:39.849 --> 03:42:42.120
about how we would present this to a customer and make

03:42:42.129 --> 03:42:45.409
certain that we get a meaningful outcome and commit

03:42:45.418 --> 03:42:48.079
the resources we need to design, administer and engineer

03:42:48.088 --> 03:42:52.250
a program um so that we can learn from this 11 time

03:42:52.259 --> 03:42:54.918
opportunity and expand the capability and potential

03:42:54.929 --> 03:42:57.979
of ad ES in the future. So again, thank you for your

03:42:57.989 --> 03:43:00.759
time and consideration. We know how important this

03:43:00.769 --> 03:43:03.918
is and we hope to contribute soon. Any questions for

03:43:04.329 --> 03:43:08.168
this panel, Greg, how many, how many megawatts were

03:43:08.179 --> 03:43:10.338
involved in your response in California and how many

03:43:10.349 --> 03:43:13.909
premises? That's a good question. I couldn't quote

03:43:13.918 --> 03:43:18.200
you um the number of premises, but the program was

03:43:18.209 --> 03:43:21.129
hundreds of megawatts. Our contribution was over 50

03:43:21.138 --> 03:43:24.110
in one utility. Uh Right now, there are three investor

03:43:24.120 --> 03:43:29.679
owned utilities, uh PG and ESDNE and S ce that participate

03:43:29.769 --> 03:43:33.440
And uh we just recently enabled our SD and E aggregation

03:43:33.450 --> 03:43:36.168
uh in the past month. Um PG and E is a little

03:43:36.179 --> 03:43:40.058
bit more long standing program and se uh Southern California

03:43:40.069 --> 03:43:43.989
Edison somewhere in between. So, so, so you just to

03:43:44.000 --> 03:43:47.668
boil it all down to layman's terms, the, the three

03:43:47.679 --> 03:43:52.989
things you need in order to pitch this to your Tesla

03:43:53.088 --> 03:43:58.069
subscribers for your services, are you need, what am

03:43:58.079 --> 03:44:00.679
I signing up for? Like, what's my maximum exposure

03:44:00.690 --> 03:44:04.759
or K's giving you that six hours of duration. Um,

03:44:06.319 --> 03:44:09.308
what is the, uh, the scale of it? You know, what am

03:44:09.319 --> 03:44:11.739
I competing in? What pool am I competing in? Three

03:44:11.750 --> 03:44:14.899
gigawatts or coats giving you that? So, you really

03:44:14.909 --> 03:44:18.540
need a budget. Is that correct? Which shows you the

03:44:18.549 --> 03:44:21.280
maximum p that you would be competing for in terms

03:44:21.290 --> 03:44:24.679
of value proposition to the premise? That's an interesting

03:44:24.690 --> 03:44:27.110
thought. And it's one I had earlier this meeting, right

03:44:27.120 --> 03:44:30.040
Because the ES program is easier to recruit because

03:44:30.049 --> 03:44:32.179
you do have a budget and it's easier to kind of figure

03:44:32.190 --> 03:44:35.299
out where the price is going to fall with rough estimate

03:44:35.540 --> 03:44:38.979
Um As illustrated by these programs, they have a fixed

03:44:38.989 --> 03:44:41.588
rate and that is much more easier to sell. It's not

03:44:41.599 --> 03:44:43.399
variable. And when you're dealing with a residential

03:44:43.409 --> 03:44:46.239
consumer, it's much more attractive when you have guaranteed

03:44:46.250 --> 03:44:49.290
rates. Um Of course, when we have a competitive style

03:44:49.299 --> 03:44:51.519
procurement that's designed towards commercial industrial

03:44:51.530 --> 03:44:54.000
consumers, they're much more comfortable signing up

03:44:54.009 --> 03:44:56.418
with the market risk given their prior exposure to

03:44:56.429 --> 03:44:58.989
ES which has been a well functioning program for years

03:44:59.229 --> 03:45:01.668
So we would prefer not necessarily a budget so that

03:45:01.679 --> 03:45:04.729
we could approximate a clearing price but a fixed rate

03:45:04.739 --> 03:45:07.860
to entice residential consumers to sign up for a first

03:45:07.870 --> 03:45:11.009
in kind Texas program that we've demonstrated has worked

03:45:11.019 --> 03:45:15.709
elsewhere and solicit that response so that we can

03:45:15.718 --> 03:45:18.269
see how it works, see what we attract because of course

03:45:18.440 --> 03:45:20.909
the uptake from a customer perspective, when they consent

03:45:20.918 --> 03:45:23.888
to participate is intrinsically tied to that dollar

03:45:23.899 --> 03:45:26.009
value. And being able to adjust that dollar value in

03:45:26.019 --> 03:45:29.138
future time periods would enable us to expand the program

03:45:29.149 --> 03:45:32.159
Presumably Christina, same questions apply to you mo

03:45:32.799 --> 03:45:36.899
So we're evaluating the parameters of, if you're in

03:45:36.909 --> 03:45:39.229
this program, you can't be in this program if you were

03:45:39.239 --> 03:45:41.099
in a rep program over the last two years. How does

03:45:41.110 --> 03:45:43.569
that preclude you from participating? And I think you

03:45:43.579 --> 03:45:45.418
heard on an earlier panel and you're doing the math

03:45:45.429 --> 03:45:47.838
about the TT US are going to have winter programs too

03:45:48.159 --> 03:45:51.530
And with TDU U programs and RCO programs, it's sort

03:45:51.540 --> 03:45:53.750
of like your easy I DS. It's never the Twain shall

03:45:53.759 --> 03:45:56.509
meet. So you're either in one or you're in the other

03:45:56.519 --> 03:45:59.129
one. So we have to evaluate all of that in terms of

03:45:59.138 --> 03:46:01.519
where we're participating. We're always going to have

03:46:01.530 --> 03:46:03.849
our demand response programs operating anyway in the

03:46:03.860 --> 03:46:07.629
winter. Um, just for economic dispatch. And I was going

03:46:07.638 --> 03:46:10.418
to pick up on something Greg had mentioned about what

03:46:10.429 --> 03:46:12.950
you have to be able to tell the customer. And from

03:46:12.959 --> 03:46:15.599
our perspective, you have to make this easy to understand

03:46:15.610 --> 03:46:18.040
for a customer. We're going to pay you this much money

03:46:18.049 --> 03:46:21.229
to participate and you as the rep have to ensure you

03:46:21.239 --> 03:46:23.860
have signed up enough customers to ensure performance

03:46:23.968 --> 03:46:26.509
because the thought that your queasy would be fine

03:46:26.519 --> 03:46:29.200
because you did not have a resource perform and you're

03:46:29.209 --> 03:46:31.679
somehow gonna flow that fine back to your customer

03:46:31.729 --> 03:46:34.620
You're gonna have to figure out some other way to recoup

03:46:34.629 --> 03:46:37.629
your risk in that. Um Because it doesn't seem like

03:46:37.638 --> 03:46:41.319
flowing ICO fines or puc fines back to an end use.

03:46:41.329 --> 03:46:43.759
Customer really seems feasible in the market that we

03:46:43.769 --> 03:46:47.349
have today. Um So you look at things like cancellation

03:46:47.360 --> 03:46:51.179
prices or um if you don't perform, you will not be

03:46:51.190 --> 03:46:54.269
able to continue into the program, um or something

03:46:54.280 --> 03:46:57.750
like that. So right now, we're just kind of evaluating

03:46:57.759 --> 03:47:00.629
which programs are available, which ones preclude performance

03:47:00.638 --> 03:47:02.860
and others. And what are the strings that come with

03:47:02.870 --> 03:47:04.918
participation in any one of those buckets?

03:47:07.269 --> 03:47:09.418
Commissioner McAdams, I just want to add also that

03:47:09.429 --> 03:47:12.989
we agree with a lot of what, uh Greg was saying about

03:47:13.250 --> 03:47:16.599
having the fixed uh payment that's well known for the

03:47:16.610 --> 03:47:20.659
customer, the program that I talked about uh in each

03:47:20.668 --> 03:47:23.209
of the test events, there was that known guaranteed

03:47:23.218 --> 03:47:28.229
payment. So that ended up being uh really a price floor

03:47:28.239 --> 03:47:32.959
and then in the actual events that happened, the, the

03:47:32.968 --> 03:47:37.129
retailers bid to provide however much the quantities

03:47:37.138 --> 03:47:40.968
were that were requested and those ended up being higher

03:47:40.979 --> 03:47:43.918
payments to the customers. So they, you know, there

03:47:43.929 --> 03:47:46.769
was upside for the customers. What was the ceiling

03:47:46.780 --> 03:47:49.909
on the range though? I'm not aware that there was a

03:47:49.918 --> 03:47:53.058
ceiling, but we could certainly check that it would

03:47:53.069 --> 03:47:53.610
be interesting

03:47:56.638 --> 03:48:00.519
questions for this panel. No, thank you. Thank you

03:48:00.530 --> 03:48:04.790
very much. Next panel will be commercial demand response

03:48:04.799 --> 03:48:08.179
first. We would like to invite Texas Rural Water Association

03:48:08.190 --> 03:48:10.088
members here. We would like to come

03:48:12.668 --> 03:48:19.069
and then grit acclaim, energy and NL and I said at

03:48:19.079 --> 03:48:20.790
that time, your time?

03:48:23.829 --> 03:48:25.629
Fantastic. Ok.

03:48:30.040 --> 03:48:30.129
Ok.

03:48:32.509 --> 03:48:35.239
And we would like Texas Rural Water Association to

03:48:35.250 --> 03:48:38.620
go first, please and introduce yourself, please. Name

03:48:39.218 --> 03:48:43.120
Ok. Is that all? Ok. I'm Bruce Alexander. I am the

03:48:43.129 --> 03:48:46.058
president of Texas Rural Water Association and I'm

03:48:46.069 --> 03:48:49.739
also currently a superintendent of a East Medina County

03:48:49.750 --> 03:48:54.280
special utility district. But in listening, all this

03:48:54.290 --> 03:48:57.759
I just want to offer something on behalf of, uh, at

03:48:57.769 --> 03:49:01.058
least my opinion and something that, uh, the members

03:49:01.069 --> 03:49:04.338
of trw a, the rural water systems, you know, a lot

03:49:04.349 --> 03:49:07.950
of us have generators. A lot of us are still trying

03:49:07.959 --> 03:49:11.819
to find and acquire generators, um, during, um, winter

03:49:11.829 --> 03:49:15.149
storm Uri, some of us that had, those were able to

03:49:15.159 --> 03:49:18.579
maintain water systems. A lot of systems didn't and

03:49:18.588 --> 03:49:21.218
even the ones that did, we had fuel problems. So it

03:49:21.229 --> 03:49:23.399
still created a lot of water issues around the state

03:49:23.409 --> 03:49:26.799
We, we plan for certain things but nobody plans for

03:49:27.019 --> 03:49:29.849
the extended attitude. We had, uh, just a little history

03:49:29.860 --> 03:49:33.739
with me. Uh, I, I worked for a municipality, uh, that

03:49:33.750 --> 03:49:37.338
owned its own electric system. Uh, 30 years ago, we

03:49:37.349 --> 03:49:41.058
had power outages based on weather, uh, when the, uh

03:49:41.259 --> 03:49:46.069
when the fish blocked the, uh the intakes to the power

03:49:46.079 --> 03:49:48.679
plants for San Antonio, we had two days, only power

03:49:48.690 --> 03:49:52.168
outages that was fixed, moved on. Uh We had a flood

03:49:52.179 --> 03:49:56.338
we lost everything for a few days and uh we got out

03:49:56.349 --> 03:49:59.049
of that, we bought generators and stood by and had

03:49:59.058 --> 03:50:01.610
everything ready. So, you know, you learn, as people

03:50:01.620 --> 03:50:03.569
have talked about, you learn as you go and you, you

03:50:03.579 --> 03:50:07.440
you adapt and overcome. But as we're moving towards

03:50:07.450 --> 03:50:11.190
these, these generators, uh I'll let, I'll let Jason

03:50:11.200 --> 03:50:14.429
here who is our deputy executive director and, and

03:50:14.440 --> 03:50:19.168
uh Eddie Lucio who is, is works for us that uh but

03:50:19.468 --> 03:50:20.860
bottom line is,

03:50:23.079 --> 03:50:25.579
I think our membership, I know myself. We're, we're

03:50:25.588 --> 03:50:28.440
willing to operate or work with the electric providers

03:50:28.450 --> 03:50:33.679
to shed power, often peak demands. Um uh I think you'll

03:50:33.690 --> 03:50:38.319
hear from uh from Jason here that combined the rule

03:50:38.329 --> 03:50:42.138
systems could probably share, shared up to 500 megawatts

03:50:43.399 --> 03:50:46.780
uh on a peak demand if we all had generators. And that's

03:50:46.790 --> 03:50:49.588
just the rule systems you add in the municipal systems

03:50:49.599 --> 03:50:53.709
you might be looking 2500 or more megawatts if we partnered

03:50:53.718 --> 03:50:56.579
with the electric providers to help provide us the

03:50:56.588 --> 03:51:00.058
generators necessary to do that. And maybe through

03:51:00.069 --> 03:51:02.239
inter local agreements, worked out some operational

03:51:02.250 --> 03:51:05.509
issues to cover the cost of fuel or, or whatever. So

03:51:05.799 --> 03:51:09.079
uh we believe we could, we could help quite a bit in

03:51:09.088 --> 03:51:11.690
shedding power during peak demands that would help

03:51:11.700 --> 03:51:14.790
folks out. So I'll let Jason, you can go from there

03:51:14.970 --> 03:51:17.838
That would help folks out. So I'll let Jason you can

03:51:17.849 --> 03:51:21.089
go from there. Yeah, uh Jason Nalo take control water

03:51:21.389 --> 03:51:24.379
Uh So as you kind of mentioned already, so with the

03:51:24.389 --> 03:51:27.729
implementation of SB three water utilities that serve

03:51:27.738 --> 03:51:30.540
more than one customer had to create an emergency preparedness

03:51:30.549 --> 03:51:33.419
plan. And part of that, they had 14 options to choose

03:51:33.428 --> 03:51:36.428
from, of how they would still continue to supply water

03:51:36.619 --> 03:51:40.259
at at least 20 P si two of those options involve generators

03:51:40.268 --> 03:51:43.689
one as being fixed and one as a mobile. So uh I

03:51:43.698 --> 03:51:47.170
couldn't gather actual hard data because that is confidential

03:51:47.359 --> 03:51:51.018
PUC C has that TCQT TM, the county and the utility

03:51:51.439 --> 03:51:54.388
So, but just with our technical assistance we've had

03:51:54.499 --> 03:51:57.018
in trying to assist everyone trying to, you know, complete

03:51:57.030 --> 03:52:01.939
these EPPS, uh I would say at least 50% are using generators

03:52:01.948 --> 03:52:04.780
to some degree. Uh Others are choosing other options

03:52:04.790 --> 03:52:06.999
or their wholesale customers to where it's just direct

03:52:07.009 --> 03:52:10.158
pressure or a multitude of those other 14 options.

03:52:10.458 --> 03:52:15.189
But I'd say at least 15 50%. And on the rule average

03:52:15.198 --> 03:52:19.139
if most of the cases, we would see maybe 100 and 25

03:52:19.149 --> 03:52:22.199
KW generator. Uh, there's a lot of generators or a

03:52:22.208 --> 03:52:24.499
lot of utilities out there that have multiple, for

03:52:24.509 --> 03:52:26.928
example, we have another board member that represents

03:52:27.208 --> 03:52:30.499
uh, Wick and Creek Sud. That's also here with us and

03:52:30.509 --> 03:52:33.389
they have, uh a handful of different ones sizing anywhere

03:52:33.399 --> 03:52:37.440
from 3 50 down to 100. So just taking estimations of

03:52:37.449 --> 03:52:41.290
an average of a 1 25 KW. There's just for easy, your

03:52:41.300 --> 03:52:45.639
math, 4600 community water systems in Texas. 50% of

03:52:45.649 --> 03:52:48.419
those, that's at least, you know, it's close to 300

03:52:48.428 --> 03:52:50.479
megawatts there. And that's on a very conservative

03:52:50.488 --> 03:52:53.738
side. Uh, taking a very load number, not including

03:52:53.749 --> 03:52:56.399
the larger cities as Bruce said, that have, you know

03:52:56.410 --> 03:52:58.699
Megawatt generators and things like that. So if there

03:52:58.708 --> 03:53:01.568
was an incentive to the water utilities to take some

03:53:01.580 --> 03:53:03.999
of that load off or even if there was a mechanism to

03:53:04.009 --> 03:53:06.520
even put some power back into the grid, uh There's

03:53:06.529 --> 03:53:08.619
another option there that is already there.

03:53:12.339 --> 03:53:14.919
Thank you, madam chair and uh, commissioners. Thank

03:53:14.928 --> 03:53:18.119
you for your service. Uh Just really quickly about

03:53:18.128 --> 03:53:21.428
trw A, we are a rural water system. Oh, Eddie, I should

03:53:21.440 --> 03:53:24.009
know that Eddie Lucio, on behalf of Texas Rural Water

03:53:24.019 --> 03:53:26.769
Association, I have to interrupt. People say that,

03:53:27.078 --> 03:53:31.229
uh, myself. But, uh, we, we represent membership from

03:53:31.239 --> 03:53:33.859
very small providers to very large providers like down

03:53:33.870 --> 03:53:37.530
in the Rio Grande Valley. And as far south as Brownsville

03:53:37.540 --> 03:53:40.408
Texas as far north as the panhandle from El Paso to

03:53:40.419 --> 03:53:44.209
Houston. Um and so where some areas started as very

03:53:44.219 --> 03:53:47.889
rural, they're now very suburban and they're widespread

03:53:47.900 --> 03:53:51.459
So it could, it's not densely concentrated in one particular

03:53:51.469 --> 03:53:54.818
area where we could provide assistance, but a statewide

03:53:55.060 --> 03:53:59.189
uh platform for you to utilize. Um happy to share more

03:53:59.199 --> 03:54:02.280
about twtrw A but I know there's more folks on the

03:54:02.290 --> 03:54:04.900
panel. Thank you. Acclaim Energy.

03:54:06.689 --> 03:54:09.419
Yes, madam commissioners. Thank you very much, gentlemen

03:54:09.429 --> 03:54:13.150
Thank you both. Um I'm John Elder, I'm the CEO of Acclaim

03:54:13.158 --> 03:54:16.298
Energy and we're a strategic energy advisor out of

03:54:16.310 --> 03:54:19.989
Houston. And the predominance of our customers are

03:54:20.068 --> 03:54:22.719
municipal utility districts and the special utility

03:54:22.729 --> 03:54:26.719
districts and the cities around the city. Ok. And uh

03:54:26.729 --> 03:54:29.540
so I wanted to appear today to be able to try to

03:54:29.548 --> 03:54:33.128
help you all to see where there may be some significant

03:54:33.139 --> 03:54:35.929
opportunities to improve the performance of your demand

03:54:35.939 --> 03:54:39.709
response programs given the type of customers I know

03:54:39.719 --> 03:54:42.578
that are there, ok. That are not being touched currently

03:54:42.759 --> 03:54:45.540
OK. Is, is that so I broke it down into a couple

03:54:45.548 --> 03:54:48.810
of different sections. OK? Of which most of them are

03:54:48.818 --> 03:54:51.900
synergistic. OK. Meaning if you did one thing is, is

03:54:51.908 --> 03:54:54.658
it would bring others into the, into your fold because

03:54:54.669 --> 03:54:57.620
I will tell you is, is that there's a tremendous amount

03:54:57.628 --> 03:55:01.408
of an opportunity in all of the municipal utility districts

03:55:01.419 --> 03:55:05.848
in Texas and there's over 1100 of them. Ok. And they

03:55:05.859 --> 03:55:09.128
range in size from small to big, but they're all subject

03:55:09.139 --> 03:55:11.750
to the SP three law that they had mentioned a little

03:55:11.759 --> 03:55:14.598
bit earlier. What they're doing to solve their problem

03:55:14.609 --> 03:55:18.348
is they're putting type two diesel generators in. Ok

03:55:18.359 --> 03:55:22.609
At their water and sewer plants. A type two, generator

03:55:22.620 --> 03:55:25.828
is great in an emergency after the grid fails, but

03:55:25.840 --> 03:55:28.818
it cannot be used in any of the emergency programs

03:55:28.828 --> 03:55:31.739
that all of everyone would like to see people participate

03:55:31.749 --> 03:55:34.919
in. OK. Now, that was a, that was a result of a

03:55:34.929 --> 03:55:40.989
law um where the generator sued the p the uh uh uh

03:55:41.049 --> 03:55:45.028
it was um the EPA OK. And they got all these little

03:55:45.037 --> 03:55:48.568
generators removed from the market because they said

03:55:48.578 --> 03:55:52.477
they emitted too much in the way of um uh pollution

03:55:52.667 --> 03:55:55.318
OK. So now what you have is is that you have an

03:55:55.328 --> 03:55:58.037
incredible amount of capacity that's sitting on the

03:55:58.049 --> 03:56:01.369
sidelines, the, the, the districts were forced to pay

03:56:01.378 --> 03:56:04.309
for. OK. And they're getting no benefit whatsoever

03:56:04.540 --> 03:56:06.710
And then what happens is is that when you don't ever

03:56:06.718 --> 03:56:09.869
use those generators when you need them, they all work

03:56:09.878 --> 03:56:12.559
OK. So they're not even being exercised, they're not

03:56:12.568 --> 03:56:15.619
even being utilized and they're not performing when

03:56:15.628 --> 03:56:19.460
they in fact are needed. OK. So the first thing that

03:56:19.468 --> 03:56:23.540
I would tell you is is that the regulatory bucket that

03:56:23.549 --> 03:56:26.159
saying that we can't use them needs to be evaluated

03:56:26.169 --> 03:56:29.210
because what's happened is, is that during the emergencies

03:56:29.429 --> 03:56:31.968
you all will go through the stages of the emergency

03:56:31.979 --> 03:56:36.739
then you will ask the, um EPA for an emergency of emergencies

03:56:36.749 --> 03:56:39.628
I'm not sure exactly what the word is, but then you

03:56:39.640 --> 03:56:42.489
would ask us to turn these things on and it was ok

03:56:42.960 --> 03:56:45.588
And the emissions didn't matter, but it doesn't happen

03:56:45.599 --> 03:56:47.580
that way they have to be enabled, people have to be

03:56:47.588 --> 03:56:50.338
ready to participate. And so that resource never gets

03:56:50.349 --> 03:56:54.318
touched. Makes sense. OK. The second item that I want

03:56:54.330 --> 03:56:56.729
you all to be aware of is, is that the other group

03:56:56.739 --> 03:57:00.549
that is not participating here is intermittent load

03:57:00.679 --> 03:57:03.489
Ok. So what's happening is in the world that we're

03:57:03.499 --> 03:57:07.179
talking about? You have lots of pumps, ok? You have

03:57:07.189 --> 03:57:10.338
that are designed to keep water pressure where it needs

03:57:10.349 --> 03:57:13.439
to be and make sure that the systems are working properly

03:57:13.510 --> 03:57:16.028
They don't run all the time, they run intermittently

03:57:16.510 --> 03:57:19.068
And what's happening is is that they are allowed to

03:57:19.080 --> 03:57:22.020
participate in your emergency response programs, but

03:57:22.028 --> 03:57:24.710
there's not enough money given the way that they're

03:57:24.718 --> 03:57:28.210
looked at in the way that the ES programs are set up

03:57:28.218 --> 03:57:31.479
Ok. So what happens is is that no intermittent load

03:57:31.489 --> 03:57:34.929
is incentivized to participate and those pumps turn

03:57:34.939 --> 03:57:37.599
on whatever they want to. So you're in the middle of

03:57:37.609 --> 03:57:40.679
an emergency event and those whole that capacity is

03:57:40.689 --> 03:57:43.669
coming online and putting stress on your grid when

03:57:43.679 --> 03:57:47.068
in fact that you need the help. Ok. It's gotta, it's

03:57:47.080 --> 03:57:50.088
it's very, very simple way to solve the problem, but

03:57:50.099 --> 03:57:52.749
none of them are going to participate, given the economics

03:57:52.760 --> 03:57:55.378
of what's happening to them when they look at these

03:57:55.390 --> 03:57:58.648
programs, which brings me to the third thing that I

03:57:58.659 --> 03:58:02.619
really want you all to think about, right? Is that

03:58:02.628 --> 03:58:07.080
customers and load is very available guys. We managed

03:58:07.088 --> 03:58:09.270
the largest cities in the state. I'm going to tell

03:58:09.278 --> 03:58:12.760
you the participation in this stuff is very, very,

03:58:12.770 --> 03:58:16.710
very low and it's strictly because of economics, it's

03:58:16.718 --> 03:58:20.869
not worth their time, right? So we've got this mechanism

03:58:20.878 --> 03:58:23.429
where you have the, um, you know, folks deciding where

03:58:23.439 --> 03:58:26.099
they're gonna, where they're gonna do things and they

03:58:26.109 --> 03:58:28.489
have no idea what's going to clear the market. But

03:58:28.499 --> 03:58:31.609
I'll promise you that only 1000 megawatts out of this

03:58:31.619 --> 03:58:34.659
whole state res program, you're not even getting near

03:58:34.669 --> 03:58:37.378
the number that it's gonna take to move load, it will

03:58:37.390 --> 03:58:40.499
move so fast if you give them the economic incentives

03:58:40.510 --> 03:58:43.609
to do it. And now it's not showing up. I don't, it

03:58:43.619 --> 03:58:45.753
doesn't matter to me what your guys are thinking. Sitting

03:58:45.765 --> 03:58:48.104
on this side of the bench of this is how much we

03:58:48.114 --> 03:58:51.174
need to pay. It's how much a customer is getting at

03:58:51.184 --> 03:58:53.784
the end of the day. That is what's going to move it

03:58:54.044 --> 03:58:56.885
And you've got lots of parties in that chain that have

03:58:56.895 --> 03:58:59.064
got to get paid to make that happen. You've got your

03:58:59.075 --> 03:59:02.174
queasy, you've got your aggregator in most cases and

03:59:02.184 --> 03:59:04.794
then you've got your customer. So the customer has

03:59:04.804 --> 03:59:07.273
to be getting enough and the load that you're going

03:59:07.284 --> 03:59:10.253
after costs money to enable. Ok, because you're talking

03:59:10.265 --> 03:59:12.713
controls, you're talking about investments of time

03:59:12.724 --> 03:59:16.700
it's significant. So if you want to go to a resource

03:59:16.710 --> 03:59:19.890
that's going to get you home, go to load. Ok. I'm on

03:59:19.898 --> 03:59:22.968
both sides of it. Go to load, it's there already. The

03:59:22.979 --> 03:59:25.080
money's already been spent for the most part for the

03:59:25.088 --> 03:59:28.260
optionality that the customers have. We just need to

03:59:28.270 --> 03:59:31.409
enable it and you need to be able to give them a

03:59:31.419 --> 03:59:34.260
dollar amount that shows up at the customer store that's

03:59:34.270 --> 03:59:37.580
big enough to move the needle and you will get your

03:59:37.588 --> 03:59:40.109
load, you will get your problem address and it will

03:59:40.119 --> 03:59:43.290
be done properly and it will be very, very cost effective

03:59:43.460 --> 03:59:46.169
And the comparison needs to be the real time price

03:59:47.009 --> 03:59:50.000
Ok. So what we're doing is is it will drive our customers

03:59:50.009 --> 03:59:52.370
there's ways of getting them to where they get the

03:59:52.380 --> 03:59:57.399
real time price when they're active. Ok. And that's

03:59:57.409 --> 04:00:00.230
what the metric needs to be. Not these other things

04:00:01.240 --> 04:00:03.088
right? Because that's what you're really paying for

04:00:04.110 --> 04:00:06.559
So anyway, those are my ideas. I'd love love to be

04:00:06.569 --> 04:00:08.389
able to have you guys to explore them. I know it's

04:00:08.399 --> 04:00:11.649
there. We have over 350 muds that are, that are our

04:00:11.659 --> 04:00:15.698
clients and um I guess probably 10 Texas cities and

04:00:15.708 --> 04:00:19.630
probably another 20 I sds and I know that the load

04:00:19.639 --> 04:00:21.698
is out there. It's just a matter of just not enough

04:00:21.708 --> 04:00:25.029
there to get him excited about making it happen. Thank

04:00:25.040 --> 04:00:26.980
you. Thank you all very much. Great.

04:00:29.958 --> 04:00:33.279
Uh Joel, you with uh Enchanted Rock. I'm representing

04:00:33.290 --> 04:00:38.659
grit. Uh We're a coalition of leading flexible generation

04:00:38.669 --> 04:00:41.889
uh domain response and micro grid resource companies

04:00:41.899 --> 04:00:45.439
including Caterpillar, Enchanted Rock Generac, Power

04:00:45.500 --> 04:00:50.779
Secure Sonova and Wars Sola. So um the way we play

04:00:50.790 --> 04:00:55.029
the market ranges quite a bit. So um we have a lot

04:00:55.040 --> 04:00:58.639
of different perspectives coming in, I guess to speak

04:00:58.649 --> 04:01:03.360
to um just upcoming winter. There's a lot of work that

04:01:03.370 --> 04:01:08.159
grip member companies have done to be well positioned

04:01:08.169 --> 04:01:12.088
to perform during the winter, whether through equipment

04:01:12.098 --> 04:01:14.588
design, you know, one of the technologies is rated

04:01:14.598 --> 04:01:21.779
down to negative 40 °F uh to perform um various engineering

04:01:21.790 --> 04:01:26.529
and operational upgrades to have the system's position

04:01:26.540 --> 04:01:30.009
for scenarios like winter storm Uri based on lessons

04:01:30.019 --> 04:01:35.338
learned and ability to deploy stored fuels or dual

04:01:35.348 --> 04:01:39.718
fuel capabilities. And for our gas fired technologies

04:01:39.730 --> 04:01:43.348
in the member companies tolerance for low gas pressures

04:01:43.360 --> 04:01:47.309
that allowed our technologies to ride through some

04:01:47.319 --> 04:01:49.299
of the issues that we saw during winter storm hearing

04:01:50.049 --> 04:01:54.799
Um All our companies are looking very closely at the

04:01:54.880 --> 04:01:57.669
RFP to see what we can bring into the market. It's

04:01:57.679 --> 04:02:02.328
a very challenging timeline, I think. Um you know for

04:02:02.338 --> 04:02:06.419
the type of demand response or behind the meter activities

04:02:06.429 --> 04:02:10.269
that we're engaged in bringing actual generating assets

04:02:10.279 --> 04:02:15.659
to bear. Um The constraints are similar to other capital

04:02:15.669 --> 04:02:19.389
r resources and that um we're working through interconnection

04:02:19.399 --> 04:02:22.078
processes and looking for opportunities to accelerate

04:02:22.088 --> 04:02:26.240
So we're looking forward to bringing some proposals

04:02:26.250 --> 04:02:32.000
there. Um I guess just a few thoughts on where we see

04:02:32.578 --> 04:02:37.730
opportunities to enhance or accelerate the deployment

04:02:37.740 --> 04:02:41.588
of incremental distributed generation and demand response

04:02:43.159 --> 04:02:46.078
even if not for this winter, maybe for the following

04:02:46.088 --> 04:02:51.939
winter. Mo first es the budget's been expanded, but

04:02:51.948 --> 04:02:57.259
I I think what we've seen is weighted average yearly

04:02:57.269 --> 04:03:01.399
clearing prices for es have not really moved up from

04:03:01.588 --> 04:03:06.899
historical uh prices and we've heard quantities are

04:03:06.909 --> 04:03:10.759
pretty similar as well right now. So there is significant

04:03:10.769 --> 04:03:14.009
money that will be left untouched from the increased

04:03:14.019 --> 04:03:17.740
budget. Um in a single clearing price mechanism. We

04:03:17.750 --> 04:03:22.929
think it makes sense to give ERCOT um the permission

04:03:22.939 --> 04:03:27.110
and guidance to send a higher price signal to draw

04:03:27.120 --> 04:03:32.809
incremental megawatts. Um I think it's, it's really

04:03:32.819 --> 04:03:37.569
set up to keep doing status quo right now in terms

04:03:37.578 --> 04:03:41.939
of distributed resource participation in the market

04:03:41.948 --> 04:03:46.458
directly. Uh The AD R program has been very exciting

04:03:46.809 --> 04:03:49.019
There are still, I think

04:03:51.659 --> 04:03:55.649
there's still more we can do. And first, we're thinking

04:03:55.659 --> 04:04:00.730
about N NPRR R 1 71 which unlocked nonspin and red

04:04:00.740 --> 04:04:05.169
down for these distribution connected assets. Uh There's

04:04:05.179 --> 04:04:10.198
a lot of interest in seeing that expanded to CRS, we

04:04:10.208 --> 04:04:17.029
think it's reasonable. And from a reliability perspective

04:04:17.040 --> 04:04:22.509
which has had concerns about it, it's safe to do so

04:04:23.370 --> 04:04:26.809
probably could use some acceleration in implementation

04:04:26.819 --> 04:04:31.069
of that NRR plus uh maybe an incremental expansion

04:04:31.078 --> 04:04:36.899
to include CRS. Um Mark also brought up the issue of

04:04:38.480 --> 04:04:42.029
controllable load resources being treated as online

04:04:42.040 --> 04:04:46.909
and having access to a $75 per Megawatt hour bid floor

04:04:47.468 --> 04:04:52.338
economically that is helpful for these types of distributed

04:04:52.348 --> 04:04:56.448
resources. And N NPRR R 131 was approved. It's just

04:04:56.458 --> 04:04:59.448
waiting implementation. So fast tracking that I think

04:04:59.458 --> 04:05:03.759
is positive for the price signals in the ADR program

04:05:03.769 --> 04:05:07.740
and for just controllable load resources in general

04:05:09.259 --> 04:05:12.759
And then in, in the last bucket of recommendations

04:05:14.049 --> 04:05:16.399
there are I think existing

04:05:18.389 --> 04:05:22.610
hurdles to entry for distributed resources and interconnections

04:05:22.620 --> 04:05:26.338
requirements and uh telemetry metering requirements

04:05:26.769 --> 04:05:30.409
I think the work that the commission started on interconnection

04:05:30.419 --> 04:05:35.448
reform uh getting that through quickly. Um And addressing

04:05:35.458 --> 04:05:39.169
some of these key sticking points for distributed resources

04:05:39.179 --> 04:05:45.649
can lower barriers to entry and uh for some of the

04:05:45.659 --> 04:05:50.338
smaller resources especially um that some of the telemetry

04:05:50.348 --> 04:05:55.069
uh requirements can be very expensive, eps metering

04:05:55.078 --> 04:05:58.809
in particular can be very expensive on a per project

04:05:58.819 --> 04:06:04.250
basis. So um we are doing some thinking on cost effective

04:06:04.669 --> 04:06:08.929
alternatives to to propose here. Thank you. And now

04:06:09.990 --> 04:06:13.458
yes, thank you. Thank you to the commission for allowing

04:06:13.468 --> 04:06:16.098
me the opportunity to speak about demand response on

04:06:16.110 --> 04:06:19.059
behalf of an L North America. My name is Madeline Gold

04:06:19.319 --> 04:06:22.000
Lalin and I am the senior Manager of Regulatory Affairs

04:06:22.009 --> 04:06:25.718
and Policy in Texas. Anel is a renewable energy developer

04:06:25.730 --> 04:06:29.569
and energy services provider. We have around 9.8 gigawatts

04:06:29.578 --> 04:06:33.889
of renewables installed across North America and 4.7

04:06:33.899 --> 04:06:36.730
gigawatts of demand response capacity under management

04:06:36.939 --> 04:06:40.208
Looking at Texas, in particular, we have 3.3 gigawatts

04:06:40.218 --> 04:06:43.360
of installed wind and solar capacity, seven operating

04:06:43.370 --> 04:06:47.290
utility scale batteries totaling about 520 megawatts

04:06:47.299 --> 04:06:51.769
or 780 Megawatt hours and around 200 megawatts of demand

04:06:51.779 --> 04:06:55.259
response capacity under management, demand response

04:06:55.269 --> 04:06:57.968
Um As we've heard from many folks here is currently

04:06:57.980 --> 04:07:01.679
undervalued and underutilized resource in Texas um

04:07:01.689 --> 04:07:06.130
could be contributing more uh towards uh energy flexibility

04:07:06.139 --> 04:07:09.040
providing resiliency and reliability benefits to the

04:07:09.049 --> 04:07:12.630
grid. Um demand response as a resource has the ability

04:07:12.639 --> 04:07:16.149
to react to rapid changes in grid conditions helping

04:07:16.159 --> 04:07:19.309
to reduce strain much quicker and at a much lower cost

04:07:19.319 --> 04:07:22.399
than building new generation assets. If you look at

04:07:22.409 --> 04:07:25.899
Texas and the ERCOT region, um they've been experiencing

04:07:25.909 --> 04:07:29.189
exponential growth in energy demand in recent years

04:07:29.198 --> 04:07:32.399
And when comparing and looking at current demand response

04:07:32.409 --> 04:07:35.838
resources versus growth and peak demand becomes apparent

04:07:35.848 --> 04:07:39.159
how little focus and attention demand response is received

04:07:39.399 --> 04:07:42.669
Um And demand response has the ability to absorb some

04:07:42.679 --> 04:07:46.290
of this growth and demand and also to create opportunities

04:07:46.299 --> 04:07:49.409
for new resources to participate, um which would lessen

04:07:49.419 --> 04:07:52.338
the burden on ERCOT in managing increasingly tight

04:07:52.348 --> 04:07:56.049
grid conditions. First, when looking at the interplay

04:07:56.059 --> 04:08:00.620
between ERCOT and TDU UDR programs, it's clear that

04:08:00.630 --> 04:08:03.380
better coordinations and communication are needed.

04:08:03.730 --> 04:08:08.750
Um First, um looking at CT this summer's barrage of

04:08:08.759 --> 04:08:11.948
conservation notices has created some fatigue as we've

04:08:11.958 --> 04:08:15.218
discussed among customers and anecdotally, we've seen

04:08:15.230 --> 04:08:18.370
some lower interest um in future participation given

04:08:18.380 --> 04:08:21.940
this uncertainty and kind of constant stream of information

04:08:22.460 --> 04:08:24.960
So some steps that ERCOT could take to remedy this

04:08:24.970 --> 04:08:28.408
situation would be to increase the level of transparency

04:08:28.420 --> 04:08:31.839
around what triggers ERCOT to issue a notice. Um And

04:08:31.849 --> 04:08:35.210
also how far in advance these notices are given um

04:08:35.220 --> 04:08:39.519
particularly for demand response, um different lengths

04:08:39.529 --> 04:08:43.128
of notice um can allow different resources to respond

04:08:43.349 --> 04:08:48.450
Um And so the the the uh advanced notice um is helpful

04:08:48.460 --> 04:08:51.450
and also duration of the notice is really important

04:08:51.460 --> 04:08:54.148
in ensuring strong customer performance during truly

04:08:54.158 --> 04:08:56.470
critical hours. We saw that towards the end of the

04:08:56.479 --> 04:08:59.700
summer as the windows started to to narrow down. Um

04:08:59.710 --> 04:09:03.059
But really honing in on what are the critical hours

04:09:03.069 --> 04:09:05.868
um based on the data that ERCOT is seeing so that we

04:09:05.878 --> 04:09:08.259
can relay that information to our customers and make

04:09:08.269 --> 04:09:11.729
sure that they're showing up. Um Other grid operators

04:09:11.739 --> 04:09:15.729
make it easier to see what resources have gone offline

04:09:15.739 --> 04:09:18.839
what is online and what is on outage. These are key

04:09:18.849 --> 04:09:21.349
pieces of data that allow us to communicate with our

04:09:21.358 --> 04:09:24.608
customers that are serving as load resources to communicate

04:09:24.618 --> 04:09:27.930
the real time situation on the grid and what to expect

04:09:28.618 --> 04:09:32.398
Um Second, looking at historical demand growth in Texas

04:09:32.408 --> 04:09:35.349
you would expect TDU U demand programs to be growing

04:09:35.358 --> 04:09:38.040
at a similar rate, but they have remained stagnant

04:09:38.388 --> 04:09:41.460
These programs are incredibly small as an overall percentage

04:09:41.470 --> 04:09:44.368
of the TDU US demand and could be expanded in both

04:09:44.378 --> 04:09:47.690
the short and long term. Expanding the procurement

04:09:47.700 --> 04:09:50.599
for these TDU U programs is definitely possible ahead

04:09:50.608 --> 04:09:54.559
of the summer 2020 24 season. But for winter expansion

04:09:54.599 --> 04:09:57.759
swift action is needed as deadlines for these TDU U

04:09:57.769 --> 04:10:01.739
programs are rapidly approaching. Um Tu programs do

04:10:01.749 --> 04:10:05.118
not require a QSE to participate. Um So there's a lower

04:10:05.128 --> 04:10:08.158
bar to entry. Um Anel obviously would still love to

04:10:08.170 --> 04:10:10.858
represent these participants as an aggregator, but

04:10:10.868 --> 04:10:15.229
it's not a requirement. Um And they could help to deploy

04:10:15.239 --> 04:10:18.769
D resources faster than an rcop program that requires

04:10:18.779 --> 04:10:22.720
a QQSE to manage the bidding along with expanding the

04:10:22.729 --> 04:10:25.180
size of the TDU programs. The commission could also

04:10:25.190 --> 04:10:27.819
assist in ensuring the pricing and parameters are set

04:10:27.829 --> 04:10:31.089
appropriately pricing products differently and appropriately

04:10:31.099 --> 04:10:34.319
depending on their value. Like ramping time or duration

04:10:34.349 --> 04:10:37.158
would result in a more predictable and reliable resource

04:10:37.170 --> 04:10:40.618
for ERCOT constant fluctuation, year to year and season

04:10:40.628 --> 04:10:43.479
to season among TDU U programs, creates uncertainty

04:10:43.489 --> 04:10:46.450
for load resources and serves as a determinant for

04:10:46.460 --> 04:10:49.819
some and now can utilize our expertise as an aggregator

04:10:49.829 --> 04:10:52.579
to advise customers on which program is best suited

04:10:52.589 --> 04:10:56.599
for giving their load profiles. But it is an unnecessary

04:10:56.608 --> 04:11:00.999
complication. Um Importantly, requiring TD us to separate

04:11:01.009 --> 04:11:04.229
out their energy efficiency and demand response programs

04:11:04.239 --> 04:11:06.759
would be helpful in making sure appropriate treatment

04:11:06.769 --> 04:11:09.628
is given to each both have a role to play but are

04:11:09.638 --> 04:11:13.559
distinct resources with distinct requirements. So requiring

04:11:13.569 --> 04:11:16.430
utility programs to follow the SP three process to

04:11:16.440 --> 04:11:19.618
get approval for DR programs would be a positive step

04:11:19.628 --> 04:11:23.950
in the right direction. Um And in enclosing demands

04:11:23.960 --> 04:11:26.858
resource demand response can be a critical component

04:11:26.868 --> 04:11:29.979
of improving grid reliability and resiliency. However

04:11:29.989 --> 04:11:32.420
appropriate attention and care must be given to how

04:11:32.430 --> 04:11:35.279
these programs are designed and managed to ensure maximum

04:11:35.290 --> 04:11:39.670
value. Texas has historically undervalued demand side

04:11:39.680 --> 04:11:43.029
resources and focused on new generation on a scale

04:11:43.148 --> 04:11:46.398
that is on building new generation assets that has

04:11:46.408 --> 04:11:49.128
resulted in rapid deployment of new generation on a

04:11:49.138 --> 04:11:51.559
scale that has not been seen in any other market across

04:11:51.569 --> 04:11:54.599
the country. And yet we are still unable to keep pace

04:11:54.608 --> 04:11:57.190
with the exponential demand growth. The state is facing

04:11:57.509 --> 04:12:00.658
demand side resources, particularly demand response

04:12:00.670 --> 04:12:03.499
is well suited to be expanded as both a short and long

04:12:03.509 --> 04:12:06.690
term solution for the types of scarcity events that

04:12:06.700 --> 04:12:09.509
we are seeing become more frequent each year. Not only

04:12:09.519 --> 04:12:12.029
can demand response answer the call during these events

04:12:12.040 --> 04:12:14.239
but it can do it in a more cost efficient way. Than

04:12:14.249 --> 04:12:15.690
almost any other solution.

04:12:22.099 --> 04:12:23.009
Thank you.

04:12:25.108 --> 04:12:26.158
Do you have any questions?

04:12:28.190 --> 04:12:31.408
Yeah, just, just to open up, I, I uh I, I had

04:12:31.420 --> 04:12:37.378
great hopes um for this panel and uh in that

04:12:39.440 --> 04:12:43.170
one of the overarching goals of this, of this workshop

04:12:43.180 --> 04:12:50.739
in my view was to expand the pool of potential dr beyond

04:12:50.749 --> 04:12:56.378
what we already harness on a seasonal basis and to

04:12:57.118 --> 04:13:01.259
and to bring the bear and develop enhanced capabilities

04:13:01.269 --> 04:13:06.888
for A's purposes, not just for their RFP, but for continuing

04:13:06.898 --> 04:13:09.940
to use this, especially over the next three years until

04:13:09.950 --> 04:13:12.309
statutory reforms begin to bear fruit.

04:13:14.799 --> 04:13:19.420
It, it is uh I think Mister Elder, what, what you brought

04:13:19.430 --> 04:13:22.999
up, we're going to have to get supporting information

04:13:23.009 --> 04:13:23.540
on that

04:13:26.450 --> 04:13:32.220
if, if all water systems are prohibited from participating

04:13:32.229 --> 04:13:37.059
in any type of energy program, that that's a major

04:13:37.479 --> 04:13:40.799
constraint and that is disconcerting to being able

04:13:40.809 --> 04:13:42.829
to manage the, manage this challenge.

04:13:44.430 --> 04:13:48.040
But I think, you know, Bruce to your point, you work

04:13:48.049 --> 04:13:53.608
with a lot of water water systems and, and you are

04:13:53.618 --> 04:13:56.960
familiar with how they operate and the regulatory constraints

04:13:56.970 --> 04:13:58.089
that they operate under,

04:14:00.658 --> 04:14:03.499
from your point of view, how much lead time as a water

04:14:03.509 --> 04:14:06.839
system do you want to see in order to be able to

04:14:06.849 --> 04:14:09.388
engage your systems and come off grid?

04:14:11.099 --> 04:14:15.059
You know, thank you for that question. I'm gonna ask

04:14:15.069 --> 04:14:17.319
you to, it's going to depend on the size of the system

04:14:17.329 --> 04:14:19.868
and the, and the individual controls that they operate

04:14:19.878 --> 04:14:23.118
under my system, for example. And it's not a large

04:14:23.128 --> 04:14:26.299
system. I have about 4000 connections that make up

04:14:26.309 --> 04:14:28.720
Actually, there's four public water systems that make

04:14:28.729 --> 04:14:33.170
it up. We have a scat system that I can my phone

04:14:33.180 --> 04:14:35.628
right now and I can turn my generators on and off.

04:14:36.398 --> 04:14:40.999
So, in a matter of minutes I can shed my load and

04:14:41.279 --> 04:14:44.138
I just want to real quick uh give a shout out if

04:14:44.148 --> 04:14:49.829
I may to my county, Medina County. Uh We, when ar of

04:14:49.839 --> 04:14:52.470
money first came out, I went to my county judge, my

04:14:52.479 --> 04:14:56.829
county commissioners and I told them help us put generators

04:14:56.839 --> 04:14:59.809
in. So we don't have a repeat of winter storm Urie

04:14:59.819 --> 04:15:04.099
So we can provide water to everybody. They shared a

04:15:04.108 --> 04:15:07.190
large portion of their money. And I can say right now

04:15:07.200 --> 04:15:10.648
that every public water system I can't say about the

04:15:10.658 --> 04:15:13.648
investor owns or the municipalities, but every rural

04:15:13.658 --> 04:15:16.569
water system Medina County has a generator and can

04:15:16.579 --> 04:15:19.368
maintain water supply during an extended power outage

04:15:20.339 --> 04:15:22.960
Most of us have those ska systems and those capabilities

04:15:22.970 --> 04:15:26.279
The larger systems do, may I ask you those skated systems

04:15:26.290 --> 04:15:28.579
that's a little bit more efficient than a type two

04:15:28.589 --> 04:15:32.259
diesel generator? Well, that's a control system. No

04:15:32.269 --> 04:15:37.319
I know. Ok. And I have generators on site that and

04:15:37.329 --> 04:15:40.470
I'm not going to argue about the environmental, but

04:15:40.710 --> 04:15:43.479
their emissions are far less than the tractors running

04:15:43.489 --> 04:15:46.529
right next. Door, so I'm not going to go there. But

04:15:46.540 --> 04:15:49.739
but as far as I can turn those on and off right

04:15:49.749 --> 04:15:53.720
here. Is your, is Medina East a particular system?

04:15:53.729 --> 04:15:55.930
Is that natural gas fed or is that diesel? No, they're

04:15:55.940 --> 04:15:57.950
diesel. Ok. So that's diesel. They're diesel. And we

04:15:57.960 --> 04:16:00.059
did that as a matter of choice because we didn't want

04:16:00.069 --> 04:16:02.729
a, right. We don't have natural gas in the area and

04:16:02.739 --> 04:16:05.839
we didn't want a large propane tank. Yeah, that's right

04:16:05.930 --> 04:16:10.089
Ok. Is, is that the on your diesel system that you've

04:16:10.099 --> 04:16:13.628
got, I assume you have type two diesels out there.

04:16:15.009 --> 04:16:16.979
You're going to ask me a technical question about the

04:16:16.989 --> 04:16:20.210
generals that I'm not going to be able to answer. But

04:16:20.220 --> 04:16:23.950
but we could probably assume that if that's the most

04:16:23.960 --> 04:16:26.069
economic, they're all, they're all the, whatever the

04:16:26.079 --> 04:16:29.049
current standard is two for whatever it is. I'm not

04:16:29.059 --> 04:16:32.569
sure. But I think to Mr McAdams point is that we have

04:16:32.579 --> 04:16:36.049
ruled water systems all over Texas and you know, we

04:16:36.059 --> 04:16:39.799
have assets in place. Yes, ma'am. And we are, we have

04:16:39.809 --> 04:16:43.148
them in place already for an established purpose. Yes

04:16:43.358 --> 04:16:45.618
ma'am. And so I think to your point and kind of what

04:16:45.628 --> 04:16:50.509
your idea was early on was, I mean, could they be available

04:16:50.540 --> 04:16:55.460
to also meet this other need, which should during,

04:16:55.470 --> 04:16:58.769
during times of where we need to kind of shave the

04:16:58.779 --> 04:17:02.499
peaks? Can these generators come on? And I think another

04:17:02.509 --> 04:17:05.559
thing that maybe you could comment on is, um, you know

04:17:05.569 --> 04:17:08.339
it's not just about the technology but it's about that

04:17:08.349 --> 04:17:11.739
boots on the ground, know how and your ability to respond

04:17:11.749 --> 04:17:15.299
very quickly, not just from the facility standpoint

04:17:15.309 --> 04:17:18.319
but also from the operating protocols. And for the

04:17:18.329 --> 04:17:21.229
experience that I think your operators have. Y yes

04:17:21.239 --> 04:17:24.739
ma'am. We, we, we, we're out there every day. We, we

04:17:24.749 --> 04:17:28.388
we know our system, we have, I have eight people that

04:17:28.398 --> 04:17:31.888
are licensed operators. And so, you know, and they're

04:17:31.898 --> 04:17:34.089
around the whole place all the time. I'm 30 miles from

04:17:34.099 --> 04:17:37.979
one end to the other. Uh, so within 30 minutes, even

04:17:37.989 --> 04:17:40.368
if they had to manually go do something, they're there

04:17:40.569 --> 04:17:46.638
um, the, uh, the answer to the question is do this

04:17:46.648 --> 04:17:51.729
we, my local electric utility when they call us and

04:17:51.739 --> 04:17:54.479
they have a planned outage or a problem area, they

04:17:54.489 --> 04:17:56.868
let us know we turn it on. We're done. We're ready

04:17:56.878 --> 04:17:59.519
to go. So it doesn't take much to let us know to

04:17:59.529 --> 04:18:02.790
get the system up and running and anybody that, any

04:18:02.799 --> 04:18:05.349
water system that has a generator and a lot of them

04:18:05.358 --> 04:18:07.559
do and a lot of them are still struggling to get it

04:18:07.569 --> 04:18:10.898
with funding and things like that. It's the same purpose

04:18:10.908 --> 04:18:13.898
Just, just let us know and it's on. What about the

04:18:13.908 --> 04:18:17.799
mutual agreements with your local cooper in those rural

04:18:17.809 --> 04:18:21.339
areas? Is, is there any interest, has there been any

04:18:21.349 --> 04:18:24.638
interest on their part? To harness you for four P management

04:18:24.898 --> 04:18:28.339
or anything to that degree. There's no, there's been

04:18:28.349 --> 04:18:30.290
no discussion on that. This is the first time I've

04:18:30.299 --> 04:18:33.759
actually brought that up. Uh, as far as can you help

04:18:33.769 --> 04:18:36.450
us shed load, can you help us do these things? Uh,

04:18:36.549 --> 04:18:39.519
I think it's something we should personally that we

04:18:39.529 --> 04:18:42.319
can explore and work with these folks. You know, it's

04:18:42.349 --> 04:18:45.118
it's kind of looking for a partner to acquire the equipment

04:18:45.128 --> 04:18:47.290
maybe looking for a partner to cover the cost of the

04:18:47.299 --> 04:18:50.599
fuel, the delta between what the cost of the electric

04:18:50.608 --> 04:18:52.940
service will be versus the cost of the fuel and maintenance

04:18:52.950 --> 04:18:55.148
of the generator, you know, kind of work in agreements

04:18:55.158 --> 04:18:58.700
like that help each other out. They want to provide

04:18:58.710 --> 04:19:01.239
the power, we also want to provide the water system

04:19:01.249 --> 04:19:04.279
So it's, it's, it's not a US versus them. It's working

04:19:04.290 --> 04:19:05.930
together in a cooper manner.

04:19:07.589 --> 04:19:11.749
So, II I have a question or maybe clarification I'm

04:19:11.759 --> 04:19:15.499
looking for. So, you know, Winter storm Urie happened

04:19:15.509 --> 04:19:19.220
there was water plants that, you know, lost water pressure

04:19:19.229 --> 04:19:23.680
because they didn't have power and we had a lot of

04:19:23.690 --> 04:19:28.700
boil water notices the state. Ok. So now SP three got

04:19:28.710 --> 04:19:32.299
passed and certain water companies or districts are

04:19:32.309 --> 04:19:37.628
required to have backup generation. And so I hear,

04:19:37.638 --> 04:19:40.509
you know, that some of the rural water districts, I

04:19:40.519 --> 04:19:42.739
guess do it on their own. Do you all fall, fall under

04:19:42.749 --> 04:19:49.089
SP three? Go ahead So it under SB three, the emergency

04:19:49.099 --> 04:19:53.658
prepare plan requirements aren't solely generator um

04:19:53.670 --> 04:19:58.019
met, you can meet them. I think there's 14 points of

04:19:58.029 --> 04:20:01.420
which you can meet them. Um It's my understanding,

04:20:01.430 --> 04:20:04.138
I think statistics show that 50% chose generation,

04:20:04.420 --> 04:20:08.069
but there were some flexibility in order to meet those

04:20:08.079 --> 04:20:10.118
requirements of that piece of legislation that are

04:20:10.128 --> 04:20:13.849
not generation uh uh based. But where that through

04:20:13.858 --> 04:20:16.710
a cooper with another electric provider or another

04:20:16.720 --> 04:20:19.690
system, interconnections and things of that nature

04:20:19.960 --> 04:20:24.489
But it wasn't just every water operator is going to

04:20:24.499 --> 04:20:28.440
have a generator. Ok. If I may, please still also the

04:20:28.450 --> 04:20:31.200
answer to the question is forced versus a choice to

04:20:31.210 --> 04:20:35.309
do it. A lot of water systems. Mine specific and I'm

04:20:35.319 --> 04:20:37.408
going to reference everyone in my county. It was a

04:20:37.420 --> 04:20:41.319
choice and every water system I talked to, it's not

04:20:41.329 --> 04:20:43.608
that they don't want to do it, they really want to

04:20:43.618 --> 04:20:46.769
do it so they can continue the service. It comes down

04:20:46.779 --> 04:20:50.388
to a cost issue and a supply issue for the generators

04:20:50.680 --> 04:20:53.529
But it's not a matter of being told you have to do

04:20:53.540 --> 04:20:56.628
it, they want to do it. So it sounds like there's tremendous

04:20:56.638 --> 04:20:59.349
opportunity, you know, in one hand, right? You know

04:20:59.358 --> 04:21:04.200
and some districts, you know, water companies have

04:21:04.210 --> 04:21:05.920
more experience than others. It sounds like you, you

04:21:05.930 --> 04:21:08.739
you're used to sort of rotating out when you need to

04:21:08.749 --> 04:21:11.398
Others may not have as much experience what I'm trying

04:21:11.408 --> 04:21:15.460
to assess is, you know, when you switch to a diesel

04:21:15.470 --> 04:21:18.118
backup generator, how long can you be on there? Like

04:21:18.128 --> 04:21:22.769
what, where's the, the, the, the point where we can

04:21:22.779 --> 04:21:25.339
you switch off for a while or you run into water pressure

04:21:25.430 --> 04:21:29.829
Here, here's the reality of it most about, I'm going

04:21:29.839 --> 04:21:35.180
to say it's probably closer to 70%. Maybe 100 the largest

04:21:35.190 --> 04:21:39.858
majority of the muds. Ok. That are out there, ok. Have

04:21:39.868 --> 04:21:44.599
used and installed diesel type two generators. Ok.

04:21:44.749 --> 04:21:47.940
And we have to have 24 hours worth of fuel on site

04:21:47.950 --> 04:21:51.450
to be able to run those. The problem is, is that you

04:21:51.670 --> 04:21:55.829
legally, ok, cannot run those generators in your ES

04:21:55.839 --> 04:22:00.569
programs or in the utility programs because of a, of

04:22:00.579 --> 04:22:04.220
a, of a regulatory twist that happened about nine years

04:22:04.229 --> 04:22:08.079
ago. And, uh, so you, you're talking about here on

04:22:08.089 --> 04:22:10.540
the rural side? Ok. I'm gonna tell you that most of

04:22:10.549 --> 04:22:13.299
ours is in the cities. Ok. Or in the counties, um,

04:22:13.309 --> 04:22:17.309
around Houston is, is that it's none of them are participating

04:22:17.319 --> 04:22:19.769
A very, very small amount of, are participating that

04:22:19.779 --> 04:22:22.599
have natural gas units. Ok. Because those are allowed

04:22:22.608 --> 04:22:25.839
to run. But the, the most cost effective unit they

04:22:25.849 --> 04:22:29.022
could install when they were required to have reliability

04:22:29.032 --> 04:22:32.242
Were these less expensive diesel type twos which are

04:22:32.252 --> 04:22:34.893
not allowed to be used. So if we can get it set

04:22:34.903 --> 04:22:38.143
up in some manner, speaking to where they can be used

04:22:38.252 --> 04:22:41.032
You will have a massive amount of participation from

04:22:41.042 --> 04:22:43.351
the municipals across the state. Does that constraint

04:22:43.361 --> 04:22:46.542
only apply to non attainment zones of the state? I

04:22:46.551 --> 04:22:49.665
don't think so. I don't think so. Now we are in a

04:22:49.674 --> 04:22:51.955
non attainment zone around Houston. So that's where

04:22:51.965 --> 04:22:54.876
we did all of our analysis work. But I'm pretty sure

04:22:54.885 --> 04:22:59.316
it's, it was nationwide. So it's a, it was a lawsuit

04:22:59.326 --> 04:23:02.965
that the EPA lost and around emissions and there was

04:23:02.975 --> 04:23:05.995
politics around all that, but that's what happened

04:23:06.004 --> 04:23:08.514
So it was a huge amount of capacity that came out of

04:23:08.524 --> 04:23:11.739
your ES program a number of years back. And if we,

04:23:11.749 --> 04:23:14.499
but the irony behind it is is that when the state gets

04:23:14.509 --> 04:23:17.229
in trouble, ok. All of a sudden they wave the white

04:23:17.239 --> 04:23:19.970
flag from the EPA that you can run anything you want

04:23:20.599 --> 04:23:22.839
but by then it's too late because you got to do all

04:23:22.849 --> 04:23:25.259
this stuff in advance. So they never get used

04:23:27.319 --> 04:23:30.279
to answer your question about the, how we operated

04:23:30.290 --> 04:23:35.049
during, uh Urie power went out, generators automatically

04:23:35.059 --> 04:23:39.658
came on. They did not go off until such time as the

04:23:39.670 --> 04:23:44.029
power was restored, stabilized. We hauled fuel consistently

04:23:44.269 --> 04:23:48.210
and, and made sure they, they never shut off. So, and

04:23:48.220 --> 04:23:51.849
and to answer the question, yes, they were running

04:23:51.858 --> 04:23:55.888
basically with the load wasn't active, the pumps weren't

04:23:55.898 --> 04:23:59.249
running. They're running us in a basically an idle

04:23:59.259 --> 04:24:02.569
mode and then as the pumps came on the load came on

04:24:02.579 --> 04:24:05.559
the, the, the generator picked up and, and ran under

04:24:05.569 --> 04:24:09.540
load, but they ran continuously during the power outage

04:24:09.829 --> 04:24:12.519
We did and anybody that has them for a public water

04:24:12.529 --> 04:24:16.339
system, they'll do the same thing because to make sure

04:24:16.349 --> 04:24:17.378
the water is flowing.

04:24:19.019 --> 04:24:21.799
So, and as far as the, the, the, the type two, I'm

04:24:21.809 --> 04:24:25.239
not aware of that. I know. So I can't answer to that

04:24:27.999 --> 04:24:30.950
So I know we want to move on to any more questions

04:24:32.749 --> 04:24:36.029
I mean, I think that the point here is that, you know

04:24:36.040 --> 04:24:38.279
in this space, there are a lot of megawatts that are

04:24:38.290 --> 04:24:41.309
sitting idle most of the time. And we see that, you

04:24:41.319 --> 04:24:44.059
know, at these rural water systems, we see them sitting

04:24:44.069 --> 04:24:47.898
next to buildings. You know, some of the times we are

04:24:47.908 --> 04:24:51.555
hand are tied by EPA regulations or sometimes 70% of

04:24:51.565 --> 04:24:55.993
the time I would say, but there are these facilities

04:24:56.003 --> 04:24:58.954
that are there that if you could tap into at some point

04:24:58.964 --> 04:25:01.364
in time, it could be pretty valuable or maybe if the

04:25:01.374 --> 04:25:04.845
secondary program that if you get a such and such an

04:25:04.854 --> 04:25:08.144
emergency case, then you have these groups ready to

04:25:08.154 --> 04:25:11.263
go. But that's, that's kind of what you're what you're

04:25:11.273 --> 04:25:16.868
looking at. Get there. The Thank you. Thank you so

04:25:16.878 --> 04:25:20.079
much. The last panel on the demand response is gonna

04:25:20.089 --> 04:25:24.768
be T IC industrial demand response, Katie. No,

04:25:29.559 --> 04:25:31.849
now I'm gonna get all these texts defending the EPA

04:25:38.929 --> 04:25:41.630
good afternoon. Commissioners, Katie Coleman for T

04:25:42.340 --> 04:25:45.860
I. Um, I guess I'm a panel of one this afternoon. Um

04:25:46.029 --> 04:25:49.438
Mark did me a favor and covered some of the sort of

04:25:49.449 --> 04:25:53.099
contexts that I had put in this deck. So I'll try not

04:25:53.110 --> 04:25:56.478
to cover that. I think the point of this slide is really

04:25:56.918 --> 04:26:00.579
um, my biggest customers do not really participate

04:26:00.590 --> 04:26:04.630
a lot in es it's more smaller industrials and large

04:26:04.639 --> 04:26:07.119
commercial customers. He talked about the budget and

04:26:07.130 --> 04:26:10.820
a little bit of expansion they've gotten. So um I'll

04:26:10.829 --> 04:26:14.349
move on to some of the other slides. So, responsive

04:26:14.360 --> 04:26:18.040
reserve service. This is the one where most industrials

04:26:18.050 --> 04:26:22.309
participate historically. Um It is procured on day

04:26:22.320 --> 04:26:25.300
ahead basis hourly. And so that's something that more

04:26:25.309 --> 04:26:28.509
sophisticated loads who need to be flexible. Um That's

04:26:28.518 --> 04:26:32.139
a better service for them than es where it's uh several

04:26:32.150 --> 04:26:36.329
months of a contract period locked in in advance. The

04:26:36.340 --> 04:26:39.208
I'm gonna address this later in more detail, but there's

04:26:39.219 --> 04:26:42.688
a limit mark mentioned the limit on how much can be

04:26:42.699 --> 04:26:46.610
provided by loads in this service relative to generation

04:26:46.619 --> 04:26:49.119
because there's a minimum that has to be provided by

04:26:49.130 --> 04:26:52.228
generation, but there is also in the protocols, uh

04:26:52.239 --> 04:26:56.650
a limit of 60% on loads that is not driven by that

04:26:56.659 --> 04:27:00.610
generation requirement. Um And so there are some megawatts

04:27:00.619 --> 04:27:04.790
that get stranded as a result of that 60% procurement

04:27:04.800 --> 04:27:08.059
limit. So I'll cover that in more detail later. Um

04:27:08.070 --> 04:27:11.840
but Mark, I agree with his numbers. Um We're getting

04:27:11.849 --> 04:27:15.998
more loads offering into this than ERCOT is buying

04:27:16.059 --> 04:27:19.090
And so the the offers are getting prorated. My members

04:27:19.099 --> 04:27:22.300
tell me that it's at about 60 to 70% of what they're

04:27:22.309 --> 04:27:26.150
offering in so that other 30 to 40% of the offered

04:27:26.159 --> 04:27:30.809
megawatts is not being utilized today. Um And Mark

04:27:30.820 --> 04:27:33.889
I think, estimated at 700 megawatts depending on some

04:27:33.900 --> 04:27:36.958
assumptions. I think it's anywhere from 700 to 1100

04:27:36.969 --> 04:27:39.918
megawatts that are not being used and I'll come back

04:27:39.929 --> 04:27:43.320
with some thoughts on that in a minute. Um The next

04:27:43.329 --> 04:27:48.018
slide, please, um I just put this on here, E Cr S

04:27:48.029 --> 04:27:51.340
and nonspin Mark highlighted this again, we're not

04:27:51.349 --> 04:27:55.849
getting a ton of load response in these services. Um

04:27:55.860 --> 04:27:58.849
The main reason that my clients have told me is that

04:27:58.860 --> 04:28:02.630
it's deployed too often and specifically to E CR S

04:28:02.639 --> 04:28:06.300
which I think a lot of them are interested in providing

04:28:06.489 --> 04:28:09.739
the deployment to and unpredictable. So I think they're

04:28:09.748 --> 04:28:12.869
looking for a little better understanding of when that

04:28:12.880 --> 04:28:15.130
service is going to be deployed and how and that might

04:28:15.139 --> 04:28:18.929
facilitate some additional megawatts from the industrial

04:28:18.938 --> 04:28:22.059
community in that service. I think nonspin is less

04:28:22.070 --> 04:28:25.449
attractive to them but, but I do hear interest in E

04:28:25.458 --> 04:28:28.708
cr s if they can get some clarity around the deployments

04:28:29.199 --> 04:28:30.389
Um Next slide.

04:28:32.630 --> 04:28:36.320
So I just wanted to talk for a second about what price

04:28:36.329 --> 04:28:38.639
response looks like from the industrial community.

04:28:38.650 --> 04:28:41.639
I think there's been some confusion and misinformation

04:28:41.650 --> 04:28:44.739
about this. So there's two things that industrials

04:28:44.748 --> 04:28:49.239
do. The first is if they're not hedged at all, an industrial

04:28:49.248 --> 04:28:53.918
world will reduce usage to avoid a high price. Um And

04:28:53.929 --> 04:28:57.840
that is a fairly limited set of industrials and megawatts

04:28:57.849 --> 04:29:01.779
that do that. It really is somebody who can curtail

04:29:01.790 --> 04:29:04.759
for a long period of time without a whole lot of notice

04:29:04.768 --> 04:29:07.518
And on a regular basis, there just aren't many industrials

04:29:07.529 --> 04:29:12.029
who operate that way. What we see more of is this second

04:29:12.040 --> 04:29:17.489
category where um the load does hedge in advance, they

04:29:17.498 --> 04:29:21.679
buy all or most of their power at some fixed price

04:29:22.059 --> 04:29:25.179
And that's because they have to plan to run around

04:29:25.188 --> 04:29:28.630
the clock, they have production quotas, they have contracts

04:29:28.639 --> 04:29:31.929
they have to meet and so they plan to do that run

04:29:31.938 --> 04:29:34.909
24 7 and they need a predictable energy cost to do

04:29:34.918 --> 04:29:37.529
that. Some have on site generation for the same reason

04:29:38.119 --> 04:29:42.029
But what happens is if we start getting into emergency

04:29:42.040 --> 04:29:45.619
conditions and prices are at the cap, they will look

04:29:45.630 --> 04:29:49.650
at what is the loss in production that I'm gonna experience

04:29:49.659 --> 04:29:53.969
compared to what I could get by liquidating that hedge

04:29:53.978 --> 04:29:57.550
given the prevailing price and you're gonna get a different

04:29:57.559 --> 04:30:00.918
answer, different times of the year, different times

04:30:00.929 --> 04:30:05.268
of the month. Um So I will tell you this summer, I

04:30:05.279 --> 04:30:09.130
think we started maxing out on some of this behavior

04:30:09.139 --> 04:30:13.070
just because we were in getting closer to those conditions

04:30:13.079 --> 04:30:15.168
or getting, you know, request to curtail and things

04:30:15.179 --> 04:30:19.009
like that. More often. I think the profile of the winter

04:30:19.018 --> 04:30:22.639
is, is very suitable to this because you're gonna see

04:30:22.650 --> 04:30:26.268
a winter storm coming in advance usually. And it's

04:30:26.279 --> 04:30:29.849
not like in the summer where it's hot every day. Right

04:30:29.860 --> 04:30:33.090
The winter storms are more isolated events. And so

04:30:33.099 --> 04:30:36.809
I think this is a really good area where you will get

04:30:36.820 --> 04:30:39.239
a good amount of response from the industrial community

04:30:39.554 --> 04:30:43.284
and maybe more so in the winter. But this last bullet

04:30:43.293 --> 04:30:45.474
that's the point they're unlikely to do this kind of

04:30:45.485 --> 04:30:49.494
thing frequently um in quick succession or for short

04:30:49.514 --> 04:30:51.764
lived events because if they take their plant down

04:30:51.775 --> 04:30:55.043
for a temporary event like this, it often takes them

04:30:55.054 --> 04:30:57.634
a long time to come back. So even though they're only

04:30:57.643 --> 04:31:00.454
needed for a short period of time, the production impacts

04:31:00.465 --> 04:31:01.603
last longer,

04:31:03.478 --> 04:31:08.688
next slide. OK. So, um I think the point of this was

04:31:08.699 --> 04:31:12.438
to try to identify areas where we could get some additional

04:31:12.449 --> 04:31:16.498
megawatts from the industrial community. I would not

04:31:16.509 --> 04:31:20.079
have, this was a market compromise that put this 60%

04:31:20.090 --> 04:31:22.518
limitation in the protocol. So I would not be coming

04:31:22.529 --> 04:31:24.590
up here like we're not gonna file this N pr R, we're

04:31:24.599 --> 04:31:28.119
not asking for this, but you asked the question. So

04:31:28.130 --> 04:31:31.659
there is this limit on, on how much responsive reserve

04:31:31.668 --> 04:31:35.239
service can be provided by loads. It's 60% it is not

04:31:35.248 --> 04:31:38.418
based on any reliability need. It was truly a market

04:31:38.429 --> 04:31:41.829
compromise. Um Loads and generation compete to provide

04:31:41.840 --> 04:31:45.320
that service. And somebody mentioned earlier, the loads

04:31:45.329 --> 04:31:48.540
often all offer in at zero because they're price takers

04:31:48.550 --> 04:31:51.239
wherever the generation clears, they're happy to take

04:31:51.248 --> 04:31:53.918
that price. They just decide whether they want to participate

04:31:53.929 --> 04:31:56.688
or not based on what they expect that price to be.

04:31:57.110 --> 04:32:01.659
Um So you could li lift this limitation. Um You still

04:32:01.668 --> 04:32:04.619
will have the minimum that's required from generation

04:32:04.630 --> 04:32:07.918
resources, so you could lift it, you could raise it

04:32:08.110 --> 04:32:10.768
Uh There are megawatts that are available that are

04:32:10.779 --> 04:32:13.518
sitting on the sidelines because of this limitation

04:32:14.290 --> 04:32:18.248
Um Mark also mentioned that sometimes you can see those

04:32:18.259 --> 04:32:22.119
additional megawatts because the loads will be armed

04:32:22.130 --> 04:32:26.540
and, and they get the online um or DC in other times

04:32:26.550 --> 04:32:28.650
in the summer. He said, you know, you're not seeing

04:32:28.659 --> 04:32:31.389
that my guess is that's typically because it's a four

04:32:31.400 --> 04:32:34.239
CP day and often on those days, they don't offer the

04:32:34.498 --> 04:32:36.619
ancillary services to the same extent either because

04:32:36.630 --> 04:32:39.998
they wanna be able to curtail whenever they want and

04:32:40.009 --> 04:32:42.949
not have to wait for ERCOT to tell them, Katie what

04:32:42.958 --> 04:32:45.909
was armed again. If you're a load resource, you have

04:32:45.918 --> 04:32:50.070
to be basically telling that you can curtail, you remember

04:32:50.079 --> 04:32:53.228
what the abbreviation stands for, it just means armed

04:32:53.239 --> 04:32:56.800
like you're ready to curtail, ok? And you're to that

04:32:57.119 --> 04:33:00.159
to basically it's not, not everything is an acronym

04:33:03.219 --> 04:33:07.590
the U Fr S. Yeah. Yeah. Um

04:33:10.759 --> 04:33:14.449
So we think some of these megawatts could potentially

04:33:14.458 --> 04:33:20.029
participate in the um RP except you've heard, I think

04:33:20.040 --> 04:33:23.079
from multiple speakers today, the restriction on the

04:33:23.090 --> 04:33:26.239
resource having been offered in, in the last two years

04:33:26.688 --> 04:33:30.469
The way this was described to me by my members is there

04:33:30.478 --> 04:33:34.119
is a, there is a consistent number of megawatts that

04:33:34.130 --> 04:33:37.110
are getting stranded that have not been offered in

04:33:37.349 --> 04:33:39.719
ancillary services, but it's not always on the same

04:33:39.728 --> 04:33:43.139
resource all the time. So probably each resource has

04:33:43.150 --> 04:33:46.400
been offered in, but you're not getting there is capacity

04:33:46.409 --> 04:33:48.860
that if you treat it all fungible has not been offered

04:33:48.869 --> 04:33:52.409
in. So, um I think just questioning whether that is

04:33:52.418 --> 04:33:54.938
a restriction that makes sense or not, I think you

04:33:54.949 --> 04:33:58.179
could get some more megawatts without that. And again

04:33:58.188 --> 04:34:00.518
if you looked at this, you would probably get more

04:34:00.540 --> 04:34:03.579
ancillary service participation even outside the RP

04:34:03.978 --> 04:34:09.498
So that's one potential area. Um Can you do the next

04:34:09.509 --> 04:34:09.900
slide?

04:34:11.550 --> 04:34:15.099
So this is something that would not be for this winter

04:34:15.199 --> 04:34:20.630
Um But it could be for future seasons. My members tell

04:34:20.639 --> 04:34:23.498
me that and I've communicated this to some of you at

04:34:23.509 --> 04:34:26.929
various times. They can provide a lot more demand response

04:34:26.938 --> 04:34:29.989
with the more notice they have a handful of industrials

04:34:29.998 --> 04:34:33.119
that provide ancillary services are pretty flexible

04:34:33.130 --> 04:34:36.369
but a lot of them to take their processes down or significantly

04:34:36.380 --> 04:34:40.820
reduce their usage. Like it takes 48 hours longer than

04:34:40.829 --> 04:34:44.090
48 hours. We don't have any type of service that is

04:34:44.099 --> 04:34:48.570
suitable for that right now. Again, for summer, I don't

04:34:48.579 --> 04:34:51.208
know how much sense this makes, but for winter, when

04:34:51.219 --> 04:34:55.268
you see a storm coming, it could be a good option to

04:34:55.279 --> 04:34:57.688
to have some additional megawatts that can commit to

04:34:57.699 --> 04:35:02.040
curtailing if you need them. Um I don't know, we would

04:35:02.050 --> 04:35:05.768
need to explore the time, the timing a little more

04:35:05.779 --> 04:35:08.188
This is just the anecdotal information I've been given

04:35:08.199 --> 04:35:10.610
from my members. That would be an ideal time frame

04:35:10.619 --> 04:35:13.829
for them, whether you could get more 24 hours or 12

04:35:13.840 --> 04:35:15.699
hours. I just don't know, that's something that would

04:35:15.708 --> 04:35:20.079
need to be explored. Um And I will tell you that again

04:35:20.090 --> 04:35:22.820
this is something that couldn't be used regularly.

04:35:22.860 --> 04:35:26.309
Probably not before ee a this would be more of like

04:35:26.320 --> 04:35:30.438
what s used to be, what about 10% of the time? Well

04:35:30.949 --> 04:35:33.659
I mean, I'd have to ask that question. I think it's

04:35:33.668 --> 04:35:36.759
they've got to evaluate lo production, right? And so

04:35:36.768 --> 04:35:39.958
that's going to be a 10 point. Is, is this really like

04:35:40.040 --> 04:35:43.509
a um more of a last resort thing or more of a

04:35:43.518 --> 04:35:45.719
conservative operations type thing? And I think it's

04:35:45.728 --> 04:35:50.119
not really suitable for the latter. Um I, I will say

04:35:50.130 --> 04:35:53.570
that while I have some members who have indicated an

04:35:53.579 --> 04:35:55.759
interest in potentially providing this, I've heard

04:35:55.768 --> 04:35:58.059
from other members that they have similar programs

04:35:58.070 --> 04:36:00.159
like this in other areas of the country that have been

04:36:00.168 --> 04:36:03.679
quite expensive. So I do think you will need to figure

04:36:03.688 --> 04:36:06.009
out, you know, what you're willing to pay for and what

04:36:06.018 --> 04:36:07.989
you're going to get. But it's something that I think

04:36:07.998 --> 04:36:11.199
on a longer, on a longer time frame than this winter

04:36:11.208 --> 04:36:12.360
could be explored

04:36:14.139 --> 04:36:18.380
next. And it's kind of, I mean, we have long lead time

04:36:18.389 --> 04:36:21.779
generation resources that solve the problem and ring

04:36:21.790 --> 04:36:24.768
and such that it's kind of the same thing. It's very

04:36:24.880 --> 04:36:28.150
much the same issue where, you know, sometimes we're

04:36:28.199 --> 04:36:30.978
wrecking resources because they take longer to commit

04:36:30.989 --> 04:36:33.478
and you can't necessarily trust them to commit in time

04:36:33.489 --> 04:36:36.300
based on market signals. It's, it's very similar to

04:36:36.309 --> 04:36:39.699
that. Um But I think there's a lot of questions, you

04:36:39.708 --> 04:36:42.958
know, when you get away from the really familiar hourly

04:36:42.969 --> 04:36:45.018
day ahead model, there's a bunch of decisions that

04:36:45.029 --> 04:36:48.579
have to be made and those would need to be discussed

04:36:49.748 --> 04:36:52.489
So like what an example is, some of these members who

04:36:52.498 --> 04:36:55.168
are interested in this said, you know, they would like

04:36:55.179 --> 04:36:59.099
a format where they don't get a capacity payment. They're

04:36:59.110 --> 04:37:02.679
not like sitting in reserve, but if they curtail they

04:37:02.688 --> 04:37:04.900
would get a payment for that. I think I heard Greg

04:37:04.909 --> 04:37:08.938
Greg suggest some similar things. Um We don't have

04:37:08.949 --> 04:37:11.849
anything that looks like that today. So we just need

04:37:11.860 --> 04:37:14.623
to understand what the pros and cons of that type of

04:37:14.634 --> 04:37:18.154
framework are. I mean, most of the time when um you're

04:37:18.165 --> 04:37:20.893
providing a compensated service, you want to make sure

04:37:20.904 --> 04:37:22.954
that you're validating the reduction, right? So you

04:37:22.965 --> 04:37:25.195
wanna make sure that people are running at a certain

04:37:25.204 --> 04:37:27.695
level. So there's all kinds of things like that that

04:37:27.704 --> 04:37:29.873
would have to be figured out. But I think the main

04:37:29.884 --> 04:37:33.684
point is with more advanced notice, there is potentially

04:37:33.695 --> 04:37:36.764
a significant additional quantity of response out there

04:37:36.775 --> 04:37:38.514
from the industrial community.

04:37:40.418 --> 04:37:46.119
Uh Next slide. Um So the final area where I think there's

04:37:46.130 --> 04:37:50.018
some additional megawatts potentially at the critical

04:37:50.029 --> 04:37:54.279
load designations. After the 2021 session, pretty much

04:37:54.290 --> 04:37:57.248
all industrials who produce their transport gas ended

04:37:57.259 --> 04:38:00.400
up on that critical designation list. We've done a

04:38:00.409 --> 04:38:04.599
couple of things that I think makes sense to allow

04:38:04.610 --> 04:38:08.880
some of these loads to participate. So in the protocols

04:38:08.889 --> 04:38:12.159
there is a provision that says if you have backup generation

04:38:12.168 --> 04:38:15.279
you're allowed to still participate. And I think that's

04:38:15.290 --> 04:38:18.998
working relatively well, but there was also an exemption

04:38:19.009 --> 04:38:24.349
offered at the railroad commission for um sites that

04:38:24.360 --> 04:38:28.699
are net users of gas, meaning that the electricity

04:38:28.708 --> 04:38:32.029
they use requires more gas than what they're producing

04:38:32.040 --> 04:38:34.978
at that site. Doesn't make sense to require them to

04:38:34.989 --> 04:38:38.300
stay online in terms of gas consumption and production

04:38:38.978 --> 04:38:42.619
Um I'm told by many of our members that I don't, I

04:38:42.630 --> 04:38:45.559
have not looked at the rule myself but they apparently

04:38:45.570 --> 04:38:49.400
have found out that they have to reapply every six

04:38:49.409 --> 04:38:53.829
months and it's quite an extensive, um, set of information

04:38:53.840 --> 04:38:56.925
that is requested from these sites to get the exemption

04:38:56.934 --> 04:39:00.583
to the, to the railroad commission. And so some of

04:39:00.594 --> 04:39:03.324
them found out in September that even though they were

04:39:03.333 --> 04:39:07.665
previously excluded, they are now back on the critical

04:39:07.675 --> 04:39:09.934
list, even though there have been no changes made at

04:39:09.945 --> 04:39:14.514
their site. And I think that they are looking at trying

04:39:14.525 --> 04:39:19.079
to reapply but the process takes some time. Um So one

04:39:19.090 --> 04:39:22.279
avenue here might be, you know, depending on the railroad

04:39:22.290 --> 04:39:25.458
commission's appetite. If somebody previously qualified

04:39:25.469 --> 04:39:28.059
and they haven't made any changes at their site for

04:39:28.070 --> 04:39:31.018
this winter, you could get them back if they didn't

04:39:31.029 --> 04:39:34.219
have to do this application process again. But I think

04:39:34.228 --> 04:39:36.610
because of the timing and process around this, some

04:39:36.619 --> 04:39:40.290
of those, those loads will still be excluded during

04:39:40.300 --> 04:39:46.958
the winter months. Um And then finally, uh we proposed

04:39:46.969 --> 04:39:50.550
this when the critical rules were the critical load

04:39:50.559 --> 04:39:53.978
rules were adopted. But I think there were so many

04:39:53.989 --> 04:39:57.179
things going on at that point, there wasn't bandwidth

04:39:57.188 --> 04:40:01.498
to really dig into this. But, um, you know, the periods

04:40:01.509 --> 04:40:04.768
where you're likely to have gas limitations are not

04:40:04.779 --> 04:40:10.489
all year and not even all winter. And so maybe sharpening

04:40:10.498 --> 04:40:12.860
our pencils and looking at are there ways that these

04:40:12.869 --> 04:40:15.659
loads could respond in some periods where there's not

04:40:15.668 --> 04:40:20.199
really a gas issue is something that I think should

04:40:20.208 --> 04:40:22.639
be looked at. Probably this is going to be more of

04:40:22.650 --> 04:40:26.400
a summer, a summer edition than winter because when

04:40:26.409 --> 04:40:28.300
we have these winter events, probably people are going

04:40:28.309 --> 04:40:31.159
to be concerned about gas. But some seasonality to

04:40:31.168 --> 04:40:34.219
this, I think could get you some year round megawatts

04:40:34.478 --> 04:40:37.840
Um, and particularly in the summer. So those are the

04:40:37.849 --> 04:40:40.119
things that I had prepared, but I'm happy to answer

04:40:40.248 --> 04:40:43.050
questions and that's a rule issue for PUC. It is a

04:40:43.059 --> 04:40:45.029
rule issue for the PUC. Yes.

04:40:48.208 --> 04:40:51.279
Well, the way, the way I think of it is the division

04:40:51.290 --> 04:40:53.880
of labor was the railroad commission is going to designate

04:40:53.889 --> 04:40:56.748
who's critical to the natural gas supply chain. But

04:40:56.759 --> 04:41:01.029
then you guys decide um what the restrictions are on

04:41:01.040 --> 04:41:06.400
those on those entities. Um So the, the one I mentioned

04:41:06.409 --> 04:41:09.329
about the net users of gas, that is a process where

04:41:09.340 --> 04:41:11.779
the railroad commission takes them out of the critical

04:41:11.790 --> 04:41:16.418
bucket. But the um on site generation treatment and

04:41:16.429 --> 04:41:20.639
the protocol is an example where the load remains designated

04:41:20.650 --> 04:41:23.978
as critical, but you all specify when and how they

04:41:23.989 --> 04:41:28.380
can be used. And so, um I don't know that the winter

04:41:28.389 --> 04:41:32.199
is often gonna be suitable for, for this type of exemption

04:41:32.208 --> 04:41:34.998
but certainly the summer would we, we very rarely see

04:41:35.009 --> 04:41:38.639
any gas concerns in the summer. Katie, do you know

04:41:38.650 --> 04:41:41.929
about how many megawatts are in that category that

04:41:41.938 --> 04:41:44.498
were formerly exempt and waiting for pre approval.

04:41:44.860 --> 04:41:47.509
I don't, I don't know the number I can tell you. It's

04:41:47.518 --> 04:41:51.748
um some of the my bigger members that have a lot of

04:41:51.759 --> 04:41:55.668
sites. So I don't know how many of their sites it tends

04:41:55.679 --> 04:42:00.009
to be um like tertiary recovery, like CO2 cutting and

04:42:00.018 --> 04:42:04.179
things like that EOR that are um more, more electric

04:42:04.188 --> 04:42:07.889
intensive types of recovery. But there's a good bit

04:42:07.900 --> 04:42:11.429
of that out there. You know, when I was doing my nosing

04:42:11.438 --> 04:42:14.029
around, I mean, it's, it might be like 100 megawatts

04:42:16.590 --> 04:42:17.179
But yeah,

04:42:20.809 --> 04:42:22.309
any more questions for Katie?

04:42:23.978 --> 04:42:27.478
Thanks for the ideas. Thank you, Katie. Now, we go

04:42:27.489 --> 04:42:31.478
back to the generation and we will bring TPP A and

04:42:31.489 --> 04:42:35.139
TEC regarding the most and the commission units

04:42:40.748 --> 04:42:43.110
and I think there are no slides. It's only verbal.

04:42:43.119 --> 04:42:47.938
Correct. Yeah. Yeah. Taylor, do you wanna go first

04:42:48.728 --> 04:42:51.869
Uh Sure. So, uh Taylor Kilroy, on behalf of the Texas

04:42:51.880 --> 04:42:55.949
Public Power Association TPP A, um we didn't want to

04:42:55.958 --> 04:42:58.938
flag, you know, when a issued their RP. A lot of our

04:42:58.949 --> 04:43:01.849
guys went through and, and try to really evaluate the

04:43:01.860 --> 04:43:05.219
status of some of those resources and for a lot of

04:43:05.228 --> 04:43:07.599
them, unfortunately, it's not a matter of chasing off

04:43:07.610 --> 04:43:10.159
raccoons. There's a reason they were decommissioned

04:43:10.168 --> 04:43:12.699
and they have been decommissioned for some time. They'd

04:43:12.708 --> 04:43:15.559
have to figure out, uh you know, getting people back

04:43:15.570 --> 04:43:19.369
out there, getting fuel supply back established. But

04:43:19.380 --> 04:43:21.429
uh rather than just provide a kind of a general update

04:43:21.438 --> 04:43:23.989
I did want to introduce Andrew Kiefer from D Municipal

04:43:23.998 --> 04:43:26.809
Electric to talk about some of the North Texas gas

04:43:26.909 --> 04:43:31.239
gas issues. Talk about some of the uh fuel supply issues

04:43:31.248 --> 04:43:32.659
that I know this commission has been really worried

04:43:32.668 --> 04:43:35.779
about. Thank you, Taylor. My name is Andrew Kiefer

04:43:35.790 --> 04:43:38.199
I work for Denton Municipal Electric madam chair. Thanks

04:43:38.208 --> 04:43:40.699
for having us coming today. Um First off, I want to

04:43:40.708 --> 04:43:43.179
thank the governor's office, the legislature, this

04:43:43.188 --> 04:43:46.978
commission, ERCOT all of you all for prioritizing weatherization

04:43:47.279 --> 04:43:50.259
Um You know, we're all very concerned about the issue

04:43:50.429 --> 04:43:53.820
and to comply and rowing the boat with all of you.

04:43:53.998 --> 04:43:56.790
We spent millions of dollars in making sure our power

04:43:56.800 --> 04:43:58.590
plant will be ready this winter. So I wanted to assure

04:43:58.599 --> 04:44:02.579
you of that first. But um, outside of that investment

04:44:02.590 --> 04:44:04.779
something that continues to concern us is natural gas

04:44:04.790 --> 04:44:08.909
supply. If you look at the maps of North Texas, you'll

04:44:08.918 --> 04:44:11.759
see the availability of what's going on up there. And

04:44:11.768 --> 04:44:14.679
I think y'all are familiar with that situation. So

04:44:14.688 --> 04:44:17.139
that's something we continue to try to find a solution

04:44:17.150 --> 04:44:20.989
for. We haven't been successful in what we've reached

04:44:20.998 --> 04:44:24.349
out to, but we continue to work in that same effort

04:44:24.360 --> 04:44:27.018
to try to resolve that situation. One of the things

04:44:27.029 --> 04:44:28.849
we've thought about, I've chatted with Taylor about

04:44:29.188 --> 04:44:34.389
is the, the curtailment list. We think in our service

04:44:34.400 --> 04:44:37.610
territory, there are probably more homes heated by

04:44:37.619 --> 04:44:40.389
electricity than they are with natural gas. And so

04:44:40.400 --> 04:44:42.800
that might be an area you might want to look at with

04:44:42.809 --> 04:44:44.869
regards to those homes and the electric supply that

04:44:44.880 --> 04:44:47.438
gets to them and the natural gas that supplies the

04:44:47.449 --> 04:44:50.090
electric units that provides the power to the homes

04:44:50.679 --> 04:44:53.639
That's all I really have to share today. And so I've

04:44:53.650 --> 04:44:57.540
heard that from multiple members that this coming winter

04:44:57.550 --> 04:45:00.349
the reason why they are seasonally mothballed is because

04:45:00.360 --> 04:45:03.050
when it hits 32 degrees, they will be curtailed. And

04:45:03.059 --> 04:45:06.739
that is an unfortunate reality of the curtailment order

04:45:06.748 --> 04:45:10.820
that was passed upstairs a few floors up a few winters

04:45:10.829 --> 04:45:14.029
ago. And so that is, that is keeping megawatts off

04:45:14.040 --> 04:45:19.570
the grid, unfortunately. Mm Julia, thank you. Good

04:45:19.579 --> 04:45:22.239
afternoon, Julia Harvey with Texas Electric co-operatives

04:45:22.248 --> 04:45:24.639
Uh a little bit of a different situation. I'm just

04:45:24.650 --> 04:45:27.540
speaking to a couple of small co op owned units that

04:45:27.550 --> 04:45:32.150
are on the list in ERCOT Srp for potentially uh returning

04:45:32.159 --> 04:45:34.748
to service. These units were, were decommissioned in

04:45:34.759 --> 04:45:39.290
2020. They are rather small. It's about 27 megawatts

04:45:39.300 --> 04:45:42.958
total. Um They, they were 57 years old when they were

04:45:42.969 --> 04:45:45.699
decommissioned. The very inefficient units, heat rate

04:45:45.708 --> 04:45:48.969
of about 25. And so there's a reason they were, they

04:45:48.978 --> 04:45:52.195
were retired. It's because they're reliable and they're

04:45:52.204 --> 04:45:55.333
not efficient. And so they got every kilowatt hour

04:45:55.344 --> 04:45:58.425
out of the unit, but the turbines haven't been looked

04:45:58.434 --> 04:46:00.893
at in years, you know, ideally you would take the entire

04:46:00.904 --> 04:46:03.925
turbine apart look at the blades, look for cracks and

04:46:03.934 --> 04:46:07.094
wear, wear and tear or at a minimum, put like a scope

04:46:07.103 --> 04:46:09.224
through the turbine a couple of times a year, none

04:46:09.235 --> 04:46:12.134
of that's been done. And so it's questionable that

04:46:12.143 --> 04:46:15.143
those units would start much less run reliably and

04:46:15.154 --> 04:46:17.284
that's why they can't be resurrected. Thank you

04:46:19.540 --> 04:46:21.059
questions for the pan up.

04:46:23.400 --> 04:46:26.449
You know, I guess on this one, this is actually more

04:46:26.458 --> 04:46:30.889
of a, a question for the guys and that is, did we

04:46:30.900 --> 04:46:32.739
think these mothball units were,

04:46:34.429 --> 04:46:36.458
did we think we were going to get more? And were they

04:46:36.469 --> 04:46:39.860
really directed at, you know, kind of this big CPS

04:46:39.869 --> 04:46:41.759
units or the Decker unit? And

04:46:43.489 --> 04:46:46.110
not all the little small ones that have been gone for

04:46:46.119 --> 04:46:48.300
a few years. And I don't know if you all have thoughts

04:46:48.309 --> 04:46:52.099
on it or, I mean, the vast majority of those units

04:46:52.110 --> 04:46:56.009
were pretty small. Yeah, CPS has already announced

04:46:56.018 --> 04:46:58.110
that uh Dey won't be able to come back and I believe

04:46:58.119 --> 04:47:00.650
that's the case with Decker that Decker will not be

04:47:00.659 --> 04:47:04.029
coming back either. And so, you know, either for economics

04:47:04.040 --> 04:47:06.599
or for non attainment reasons or just, you know, like

04:47:06.610 --> 04:47:10.130
Julie mentioned age, uh those units will not come back

04:47:11.958 --> 04:47:17.309
So for either the co-operatives or public power, do

04:47:17.320 --> 04:47:20.259
you see any other alternatives right now to getting

04:47:20.268 --> 04:47:23.918
more megawatts on system for winter? You guys have

04:47:23.929 --> 04:47:28.268
the most capabilities you are governed by your Cooper

04:47:28.400 --> 04:47:30.728
boards or your city councils,

04:47:32.380 --> 04:47:36.869
you are vertically integrated, you have a lot of capabilities

04:47:36.889 --> 04:47:37.518
What do you think?

04:47:39.989 --> 04:47:44.340
Yes, if anybody can control their load, you can. I

04:47:44.349 --> 04:47:48.139
agree. We have a business model that works well with

04:47:48.150 --> 04:47:53.449
this concept. Yes. And so I don't, I don't, I'm not

04:47:53.458 --> 04:47:57.070
aware of any, you know, additional dispatchable generation

04:47:57.079 --> 04:47:59.889
especially at a large scale that can be accelerated

04:47:59.900 --> 04:48:02.409
or brought online for this winter. But on the demand

04:48:02.418 --> 04:48:05.719
side, like we just heard for the last few panels, that

04:48:05.728 --> 04:48:08.110
is something cooperators are very much interested in

04:48:08.119 --> 04:48:11.639
this aggregated D er potential. And a number of my

04:48:11.650 --> 04:48:15.429
members are actively investing and engaging with partners

04:48:15.438 --> 04:48:19.090
and vendors to achieve that. And to enable a project

04:48:19.099 --> 04:48:21.570
that can bid into ERCOT, we view it as a win, win

04:48:21.804 --> 04:48:25.235
Our members get compensated the co op saves money,

04:48:25.244 --> 04:48:28.123
it supports reliability. There's a guy in the room

04:48:28.134 --> 04:48:30.543
from Bandera, I want to mention them, they have a really

04:48:30.554 --> 04:48:33.603
innovative cutting edge program that allows this granular

04:48:33.614 --> 04:48:36.543
visibility and to load. But there are challenges with

04:48:36.554 --> 04:48:40.094
this. And so we are we, you know, this RFP has prompted

04:48:40.103 --> 04:48:42.954
us to kind of look at it much more closely and sharpen

04:48:42.965 --> 04:48:46.114
the pencil on it. You need a number of different moving

04:48:46.123 --> 04:48:49.594
parts in place that are are hard to just stand up so

04:48:49.804 --> 04:48:51.938
I can go through them just very briefly, you need a

04:48:51.949 --> 04:48:55.639
viable distributed energy resource management derms

04:48:55.650 --> 04:49:00.418
platform. There's a lot of providers out there, but

04:49:00.820 --> 04:49:03.179
there's not a lot of maturity. So it looks good on

04:49:03.188 --> 04:49:05.458
paper, but it's kind of limited functionality kind

04:49:05.469 --> 04:49:08.429
of vaporware as it's called. You also need controllable

04:49:08.438 --> 04:49:12.779
devices that are set up for this purpose. You need

04:49:12.790 --> 04:49:17.360
stable internet and wifi because we have co op members

04:49:17.369 --> 04:49:20.570
with batteries or generators. It might be in a barn

04:49:21.025 --> 04:49:23.755
of an acre away. You need Wi Fi for the connectivity

04:49:23.853 --> 04:49:26.594
but you guys are installing broadband now. Exactly

04:49:26.603 --> 04:49:29.415
So there is a lot of opportunity. Yeah, it goes hand

04:49:29.425 --> 04:49:33.025
in hand. But again, it's just, there's a lot most importantly

04:49:33.034 --> 04:49:35.415
you need buy in from the coop's membership because

04:49:35.425 --> 04:49:38.594
there's risk and an uncertain value proposition. You

04:49:38.603 --> 04:49:41.695
need to navigate a bidding strategy with limited information

04:49:41.704 --> 04:49:45.204
a QSE relationship, all of that. And so, you know,

04:49:45.215 --> 04:49:48.224
there is, I hear about it all the time from our members

04:49:48.235 --> 04:49:51.728
There's significant interest, but again, you know,

04:49:51.779 --> 04:49:54.650
managing the expectations, we are relatively small

04:49:54.659 --> 04:49:58.259
low density 6 m per mile on average. So there's some

04:49:58.268 --> 04:50:02.188
scaling challenges and probably just not as much potential

04:50:02.199 --> 04:50:05.349
as a large metropolitan area, but I do think it's on

04:50:05.360 --> 04:50:07.998
the horizon. Um So hopefully I can come back soon and

04:50:08.009 --> 04:50:11.860
report back on on the reality of that. Um But you know

04:50:11.869 --> 04:50:14.458
that they're looking at it closely some of the parameters

04:50:14.469 --> 04:50:18.018
in the RFP, make it hard to do. There's also some issues

04:50:18.029 --> 04:50:21.529
with the, the OEMs the equipment manufacturers and

04:50:21.540 --> 04:50:25.708
sort of interoperability there and open access that

04:50:25.719 --> 04:50:28.449
can also make it hard to stand something up quickly

04:50:28.540 --> 04:50:31.639
So I know ERCOT has contemplated much of this and I

04:50:31.650 --> 04:50:34.268
and I know that'll, they'll delve into that through

04:50:34.279 --> 04:50:38.679
the RFP Q and A. But if the standards are relaxed,

04:50:38.699 --> 04:50:42.458
and again, the PUC can work with our partner agencies

04:50:42.469 --> 04:50:47.400
and figure out what regulatory forbearance may be exercised

04:50:47.409 --> 04:50:51.909
on existing regulatory constraints. And you can harness

04:50:51.918 --> 04:50:54.790
the power of some of these hub and hub and spoke systems

04:50:54.800 --> 04:51:00.498
in, in these areas of Texas. Theoretically, you could

04:51:00.509 --> 04:51:02.938
bring something on by Christmas

04:51:04.650 --> 04:51:09.248
theoretically in practice. I don't know. Well, the

04:51:09.619 --> 04:51:11.429
person from Mender is shaking his head.

04:51:13.739 --> 04:51:18.418
I would like to offer your opinion. And of course,

04:51:18.429 --> 04:51:21.349
some of this is unfortunately, beyond the commission's

04:51:21.619 --> 04:51:24.018
scope, we are looking at non attainment issues and

04:51:24.029 --> 04:51:27.699
those are federal issues that are ultimately also we

04:51:27.708 --> 04:51:29.840
can work with our partners and we'll do our best. I

04:51:29.909 --> 04:51:30.409
don't know that

04:51:33.719 --> 04:51:38.570
Julia, when you said Oes, are you specifically talking

04:51:38.579 --> 04:51:45.550
about like a technology of storage provider that um

04:51:46.579 --> 04:51:49.840
yes, I am a dominant provider of behind the meter storage

04:51:49.869 --> 04:51:52.840
Yes. So the question here that's been brought to my

04:51:52.849 --> 04:51:55.458
attention a few times, Greg, I'm looking at you because

04:51:55.469 --> 04:52:00.208
of, of Tesla, which is they have their, they're managing

04:52:00.219 --> 04:52:06.409
the power walls and in your area or Bandera area, wherever

04:52:06.418 --> 04:52:08.090
they can't control them because they don't have the

04:52:08.099 --> 04:52:11.699
system to do. So. Is that something that. Yeah, please

04:52:11.708 --> 04:52:12.929
come up. That would be great, Greg

04:52:17.929 --> 04:52:23.329
Greg Turner Tess Electric. Um We have systems in place

04:52:23.340 --> 04:52:27.820
to deploy our assets in the AD R program. And uh this

04:52:27.829 --> 04:52:31.820
was a first of kind real time, five minute dispatch

04:52:32.228 --> 04:52:36.418
with sub second response time from the assets. Uh that's

04:52:36.429 --> 04:52:39.259
still in-house and that's something we're working to

04:52:39.268 --> 04:52:43.360
expand to third parties. Um and doing so for ourselves

04:52:43.369 --> 04:52:46.279
we can be much less elegant and, and package something

04:52:46.290 --> 04:52:49.998
that works. But when we deliver a product to uh other

04:52:50.009 --> 04:52:52.248
entities that have to use that on a day ahead and real

04:52:52.259 --> 04:52:55.070
time basis, it takes a little bit more time. But we're

04:52:55.079 --> 04:52:58.320
actively having discussions with uh noncompetitive

04:52:58.329 --> 04:53:01.668
territories because they do have a captive customer

04:53:01.759 --> 04:53:03.998
They do have the longevity of that relationship and

04:53:04.009 --> 04:53:07.369
they can make that investment. And we're going to investigate

04:53:07.380 --> 04:53:09.809
ways we can replicate the functionality that we've

04:53:09.820 --> 04:53:14.050
built for ourselves, for their QSC so that they can

04:53:14.059 --> 04:53:16.809
participate in a manner that we can participate in

04:53:16.820 --> 04:53:21.009
And that was largely um veiled. But part of my commentary

04:53:21.018 --> 04:53:24.809
in that uh we're committed to the AD E space and that

04:53:24.820 --> 04:53:28.559
functionality or at least making it available externally

04:53:28.739 --> 04:53:32.650
um can't necessarily happen overnight, but it can happen

04:53:32.659 --> 04:53:35.188
quickly, probably quicker than the commercial arrangements

04:53:35.199 --> 04:53:39.168
could happen in the next six weeks. Much less the connectivity

04:53:39.179 --> 04:53:42.110
with ERCOT, which follows a network model load schedule

04:53:42.119 --> 04:53:45.728
which is a minimum of 45 to 90 days depending on when

04:53:45.739 --> 04:53:49.449
you submit that capability and registering an ad, er

04:53:49.458 --> 04:53:51.929
isn't as onerous as a traditional resource, but it

04:53:51.938 --> 04:53:55.349
still takes time. Yeah, I didn't mean to put you on

04:53:55.360 --> 04:53:58.369
the spot here, but I mean, clearly I'm very rehearsed

04:53:58.380 --> 04:54:02.179
on that clearly where we have these, these Noy and

04:54:02.188 --> 04:54:06.478
Co ops that I would suggest that from my understanding

04:54:06.489 --> 04:54:09.168
probably power walls are the most common type of storage

04:54:09.179 --> 04:54:12.949
facility. I think gene is, is another one that's out

04:54:12.958 --> 04:54:16.409
there quite a bit but that in your electrical service

04:54:16.418 --> 04:54:19.478
territories, those, you know, you have to have some

04:54:19.489 --> 04:54:22.809
ability to be able to help them participate in this

04:54:22.820 --> 04:54:26.099
function. You know, as we go forward and we didn't

04:54:26.110 --> 04:54:28.070
create AD R for,

04:54:30.150 --> 04:54:33.150
for captive customers for it was, it was never intended

04:54:33.159 --> 04:54:36.029
to be, you know, captive for just that storage. We

04:54:36.040 --> 04:54:40.329
have AD R right now is timely. So if we could increase

04:54:40.340 --> 04:54:45.498
that participation and thus engagement, it would be

04:54:45.509 --> 04:54:49.688
helpful. But so Julie, you mentioned uh Banda and I

04:54:49.699 --> 04:54:52.380
know that they're not only, you know, working on demand

04:54:52.389 --> 04:54:56.360
response but also um you know, the interconnectivity

04:54:56.369 --> 04:54:59.259
through um broadband. And so I was just wondering,

04:54:59.268 --> 04:55:01.369
I saw you kind of shaking your head when we were asking

04:55:01.380 --> 04:55:03.159
you know what the potential was, if you could just

04:55:03.168 --> 04:55:06.009
take a couple of minutes cause you know, I've been

04:55:06.018 --> 04:55:08.978
there and seen some things y'all are up to. Uh thank

04:55:08.989 --> 04:55:11.279
you madam chair. I'm John Pellino, General Counsel

04:55:11.290 --> 04:55:15.259
from Bandera Electric co-operative. Um Yes, to answer

04:55:15.268 --> 04:55:18.050
your question. I guess going back to theoretically

04:55:18.059 --> 04:55:22.188
could we bring a resource online by Christmas? I think

04:55:22.199 --> 04:55:25.139
the answer at Bandera Electric is the answer is yes

04:55:25.150 --> 04:55:30.139
we could uh given the comments by Tesla. Uh if there

04:55:30.150 --> 04:55:33.840
was a platform that we could tap into uh to be able

04:55:33.849 --> 04:55:38.599
to uh market to our members a program do enrollments

04:55:38.610 --> 04:55:40.790
I think theoretically we could get that going. We've

04:55:40.800 --> 04:55:43.809
been working on this, I'm on the AD R pilot task force

04:55:44.079 --> 04:55:47.380
Um And we've been working on this for over a year now

04:55:47.650 --> 04:55:51.759
Um And so if we had the access to the power walls

04:55:51.768 --> 04:55:54.099
and I mentioned those because at Beder Electric, we

04:55:54.110 --> 04:55:58.540
probably have about 1.5 megawatts. We're a small utility

04:55:58.550 --> 04:56:02.800
in this room. Um But we have about 1.5 megawatts of

04:56:02.809 --> 04:56:06.938
behind the meter storage capacity. Almost a Megawatt

04:56:06.949 --> 04:56:10.130
of that are power walls and bandera electric is not

04:56:10.139 --> 04:56:14.320
only an electric Cooper provided retail electricity

04:56:14.529 --> 04:56:17.813
but we, we do provide fiber to the home broadband internet

04:56:17.824 --> 04:56:22.165
access service and we also are a installer and seller

04:56:22.175 --> 04:56:26.603
of energy distributed generation and storage facilities

04:56:26.614 --> 04:56:29.255
We've been a certified Tesla Powerwall installer since

04:56:29.264 --> 04:56:34.639
2017. Almost 60% of the power walls were sold to our

04:56:34.650 --> 04:56:38.119
members by Beder Electric Cooper. So we have a great

04:56:38.130 --> 04:56:40.309
relationship with those members. I can't speak for

04:56:40.320 --> 04:56:43.639
them individually. But I think if we marketed a program

04:56:43.659 --> 04:56:48.199
and had access to the power walls as a fleet that we

04:56:48.208 --> 04:56:51.050
theoretically could put together a program by Christmas

04:56:51.309 --> 04:56:54.369
Um We've developed a behind the meter energy monitoring

04:56:54.380 --> 04:56:58.458
program that does device level monitoring in real time

04:56:58.739 --> 04:57:01.668
Uh We've measured just by installing that platform

04:57:01.679 --> 04:57:05.518
to our members that they save on a monthly basis, 10%

04:57:05.529 --> 04:57:09.909
of their energy use. Um So on an average uh use uh

04:57:09.918 --> 04:57:14.059
for our members is 1 1238 kilowatt hours per month

04:57:14.340 --> 04:57:16.360
Uh So we can just do the math from there. And that's

04:57:16.369 --> 04:57:19.860
the kind of savings by by providing real time energy

04:57:19.869 --> 04:57:22.320
feedback to our members. And you combine that with

04:57:22.329 --> 04:57:25.418
the Thermostat program and energy storage. And I think

04:57:25.429 --> 04:57:28.579
we could uh we're currently doing a lot of that. And

04:57:28.590 --> 04:57:31.208
so adding the batteries to that we could, you know

04:57:31.219 --> 04:57:35.360
we would make a small dent into the, to the to the

04:57:35.369 --> 04:57:38.900
numbers that you're looking for. But I think we could

04:57:38.909 --> 04:57:42.418
show other people across the state, including our investor

04:57:42.429 --> 04:57:46.478
and friends, how to do it, punch above your weight

04:57:48.090 --> 04:57:51.040
We try to, we are the uh cowboy capital of the world

04:57:55.639 --> 04:57:59.610
Any more questions for this panel? Thank you. Thank

04:57:59.619 --> 04:58:03.418
you so much. Last panel in the resources is resources

04:58:03.429 --> 04:58:06.228
in the queue from bridge Tina Lee.

04:58:16.800 --> 04:58:20.179
Good afternoon. Uh madam chair and uh commissioners

04:58:20.188 --> 04:58:23.529
Um I am uh Tina Lee with uh vice president of um

04:58:23.540 --> 04:58:26.349
asset management at Watt Bridge. And to remind Watt

04:58:26.360 --> 04:58:30.650
Bridge is the wholly owned um IP P of pro energy Services

04:58:30.719 --> 04:58:33.219
And within the last three years, we've built out a

04:58:33.228 --> 04:58:36.929
1900 Megawatt portfolio of fast start dispatchable

04:58:36.938 --> 04:58:39.300
thermal generation in and around the Houston area.

04:58:39.679 --> 04:58:43.059
Um And we do have a couple of more uh projects under

04:58:43.070 --> 04:58:46.938
construction right now. Um on the topic of within the

04:58:46.949 --> 04:58:50.998
interconnection queue, uh It's approximately 480 megawatts

04:58:51.009 --> 04:58:55.938
um that will come online second quarter of 2024. Unfortunately

04:58:55.949 --> 04:58:59.639
just given the nature of actual generation and so forth

04:58:59.650 --> 04:59:02.179
there's nothing we can do to accelerate it. You know

04:59:02.188 --> 04:59:05.809
we, we saw this RFP. Um We did take a look at

04:59:05.820 --> 04:59:08.860
the opportunity to bring on maybe a couple of new units

04:59:09.168 --> 04:59:13.079
Um The, the, the gas supply is there, the infrastructure

04:59:13.090 --> 04:59:15.929
is there, we can probably rustle up some engines and

04:59:15.938 --> 04:59:20.079
so forth. The reality is um the uh transmission um

04:59:20.090 --> 04:59:23.239
interconnection uh just cannot be accelerated. So,

04:59:23.498 --> 04:59:27.360
um as you are well aware, these projects are, you know

04:59:27.369 --> 04:59:31.279
years in the making, we actually took um we committed

04:59:31.290 --> 04:59:35.439
to these projects at the, at the end of 2022. And so

04:59:35.449 --> 04:59:39.378
really within 18 months of that commitment, we will

04:59:39.390 --> 04:59:43.199
be online, but it is very difficult even for us um

04:59:43.208 --> 04:59:46.378
to, to shave off six months or so, to be able to

04:59:46.390 --> 04:59:51.019
make um this RFP, I would say that um on, on behalf

04:59:51.029 --> 04:59:54.239
of my parent company, which is an E PUC manufacturing

04:59:54.310 --> 04:59:57.409
One of the products that they do provide is uh mobile

04:59:57.418 --> 05:00:01.810
generation. Um And we did submit some que a question

05:00:01.819 --> 05:00:06.779
to the winner RFP. It's question 12. Um in terms of

05:00:06.859 --> 05:00:09.859
is there the opportunity for some of these mothball

05:00:09.869 --> 05:00:14.609
generation units to um install mobile generation units

05:00:14.899 --> 05:00:17.510
Um Again, this would be more on an equipment side,

05:00:17.519 --> 05:00:20.628
not as a competitive general would not be done under

05:00:20.640 --> 05:00:25.239
Watt Bridge, but it um one would be helpful to get

05:00:25.248 --> 05:00:28.310
an introduction to some of these uh resource entities

05:00:28.510 --> 05:00:31.949
Um just to evaluate their interest level and their

05:00:31.958 --> 05:00:35.668
infrastructure in terms of the gas supply, water supply

05:00:35.930 --> 05:00:39.449
and actual physical footprint. And then from there

05:00:39.458 --> 05:00:43.119
um they can either work with my parent company or any

05:00:43.128 --> 05:00:46.290
other really um any other mobile generator provider

05:00:46.470 --> 05:00:49.838
to see if that's possible. I would expect that a mobile

05:00:49.850 --> 05:00:52.708
generator where you only need it for a couple of months

05:00:52.790 --> 05:00:56.019
might be easier and less expensive to bring online

05:00:56.029 --> 05:00:59.189
versus trying to bring back mothballs um units and

05:00:59.199 --> 05:01:03.769
so forth. So, uh again, uh Watt Ridge, we we are um

05:01:03.779 --> 05:01:06.338
working as fast as we can to continue to build out

05:01:06.350 --> 05:01:10.208
our portfolio. Um And then uh pro energy itself just

05:01:10.220 --> 05:01:13.310
to kind of leave you with some thought for the next

05:01:13.319 --> 05:01:17.529
RP uh opportunity that ERCOT is considering um mobile

05:01:17.540 --> 05:01:20.470
generation at some of these small fault sites. Um In

05:01:20.479 --> 05:01:23.540
addition to A as there have been comments about maybe

05:01:23.549 --> 05:01:28.609
relaxing um the interconnection process for these mobile

05:01:28.619 --> 05:01:32.790
generation. Maybe that's an opportunity there to accelerate

05:01:32.799 --> 05:01:37.378
the process. In terms of if the you know, the resource

05:01:37.390 --> 05:01:40.409
entities were able to get to uh commercial agreement

05:01:40.418 --> 05:01:44.229
with the mobile generation. I think physical mobilization

05:01:44.239 --> 05:01:47.529
to the site is anywhere from 2 to 4 weeks. But um

05:01:47.540 --> 05:01:51.359
I expect that the paperwork would take longer and then

05:01:51.369 --> 05:01:54.729
uh the interconnection queue would have some um challenges

05:01:54.739 --> 05:01:55.088
too.

05:01:56.628 --> 05:01:59.918
Question for any questions. Questions for Tina,

05:02:01.769 --> 05:02:03.739
are you sure you can't speed it up?

05:02:05.519 --> 05:02:08.829
You can speak with CenterPoint if you like.

05:02:11.409 --> 05:02:11.470
Oh

05:02:13.220 --> 05:02:14.540
oh maybe we can.

05:02:16.949 --> 05:02:20.220
So that would beg the question. Is it a physical

05:02:22.890 --> 05:02:27.998
construction issue on your side of the? No, I think

05:02:28.010 --> 05:02:31.859
most of the construction is complete on our side. You

05:02:31.869 --> 05:02:34.838
know, it's really working with the transmission system

05:02:34.850 --> 05:02:38.529
and trying to get that interconnected faster. And,

05:02:38.540 --> 05:02:42.149
and I think this is one of the points that we've emphasized

05:02:42.159 --> 05:02:45.600
in our comments to the Texas Energy Fund is having

05:02:45.609 --> 05:02:50.189
the PUC stand behind us in terms of trying to accelerate

05:02:50.199 --> 05:02:53.269
the interconnection that would be immensely helpful

05:02:53.279 --> 05:02:53.689
as well.

05:02:56.458 --> 05:02:59.128
So, so again, no commitments today. This is not

05:03:00.859 --> 05:03:01.299
for him.

05:03:03.180 --> 05:03:07.329
I was just gonna say so. So the, so the question is

05:03:07.338 --> 05:03:12.088
um if, if ah

05:03:13.760 --> 05:03:15.180
what did the center point come out?

05:03:17.359 --> 05:03:17.378
Yeah,

05:03:19.430 --> 05:03:21.088
noted CenterPoint is leaving the room.

05:03:24.399 --> 05:03:28.329
We'll address that offline, but that teed up a good

05:03:28.338 --> 05:03:32.248
issue. Tina, thank you. The Q and A says that doesn't

05:03:32.260 --> 05:03:34.489
think that the interconnection requirements could be

05:03:34.498 --> 05:03:37.909
Manor Planning Guide in time too. So I don't know if

05:03:37.918 --> 05:03:40.269
that's because the T dsps are reporting that to ERCOT

05:03:40.279 --> 05:03:43.659
or they can answer that during the Q and A.

05:03:46.100 --> 05:03:48.260
No more questions. Thank you. Thank you. Thank you

05:03:48.369 --> 05:03:52.529
so much. Last topic on this category is generic transmission

05:03:52.540 --> 05:03:56.989
constraints and quart, Dan Woodfin and Omega Rafael

05:03:57.369 --> 05:03:57.729
Kalho.

05:04:02.029 --> 05:04:02.790
Me if I open

05:04:10.540 --> 05:04:14.689
good afternoon again and we've been with our guy. Um

05:04:15.189 --> 05:04:17.378
Weren't sure exactly what y'all wanna talk about on

05:04:17.390 --> 05:04:21.378
this one but um kind kind of some, a couple of slides

05:04:21.390 --> 05:04:24.739
I guess if you compare to the next one, G TC S

05:04:24.748 --> 05:04:27.739
are basically where you have a limitation on power

05:04:27.748 --> 05:04:30.199
flows across the system that aren't because of a line

05:04:30.208 --> 05:04:33.069
being overloaded, but they're because of some other

05:04:33.079 --> 05:04:35.213
issue like stability or

05:04:37.174 --> 05:04:40.324
something like that that we can't model and SCED. So

05:04:40.333 --> 05:04:43.333
we model these in such a way that, that the security

05:04:43.345 --> 05:04:46.055
constrained economic dispatch can take advantage of

05:04:46.064 --> 05:04:49.165
as much transfer capabilities as it can economically

05:04:49.265 --> 05:04:52.354
but still maintain the reliability of the system. And

05:04:52.364 --> 05:04:55.814
with the more and more inverter based resources, we've

05:04:55.824 --> 05:04:58.924
had an increase in the number of these G TC S. Currently

05:04:58.935 --> 05:05:04.310
we have 18 of them. Um I've added some recent updates

05:05:04.319 --> 05:05:07.779
There really hasn't been a lot of new ones lately in

05:05:07.790 --> 05:05:11.498
the last month or so. But we do update limits when

05:05:11.510 --> 05:05:14.088
there are new units come online or something like that

05:05:14.699 --> 05:05:16.019
Um, next slide

05:05:17.619 --> 05:05:21.378
and basically a lot of them are in the areas where

05:05:21.390 --> 05:05:25.319
we've seen a large expansion in new generation. Basically

05:05:25.329 --> 05:05:29.998
West Texas, South Texas, there's a few in the rest

05:05:30.010 --> 05:05:32.369
of the state, but that's primarily where they are.

05:05:32.970 --> 05:05:36.569
So I'll be happy to answer any questions though.

05:05:38.930 --> 05:05:44.049
Ok. I think the thought here is there are existing

05:05:44.060 --> 05:05:47.100
megawatts on the system. But if they're stuck behind

05:05:47.109 --> 05:05:52.049
a GTC, how could those be available during the winter

05:05:52.060 --> 05:05:55.668
months rather than just stuck behind a GTC? And some

05:05:55.680 --> 05:05:59.220
of these GCS have been in place for many, many years

05:05:59.470 --> 05:06:03.019
and I know you all have the ability to the requirement

05:06:03.248 --> 05:06:08.519
to, to create exit strategies, but there's no commitment

05:06:08.859 --> 05:06:11.579
to solve the exit strategy to implement the exit strategy

05:06:11.588 --> 05:06:14.540
just to create it. And, you know, I think there would

05:06:14.549 --> 05:06:18.850
be some, maybe it's this summer, maybe, or maybe this

05:06:18.859 --> 05:06:21.918
winter or, or not other ideas that might help that

05:06:21.930 --> 05:06:27.029
But clearly, I think the fact that the requirement

05:06:27.040 --> 05:06:30.628
that there's a exit strategy doesn't mean that it should

05:06:30.640 --> 05:06:37.659
fall on not doing any work to solve the GTC. So ailes

05:06:37.668 --> 05:06:39.029
on this panel too, right?

05:06:41.869 --> 05:06:42.549
Slides,

05:06:46.668 --> 05:06:50.220
hello, say your name and your company? Yes. Uh My name

05:06:50.229 --> 05:06:54.970
is Rafael Carvalho. I work for Omega Energia. Uh So

05:06:54.979 --> 05:06:57.409
first of all, thank you for the opportunity of speaking

05:06:57.418 --> 05:07:02.208
here. Uh I have just two slides trying to show that

05:07:02.220 --> 05:07:07.220
we can uh quickly release uh one gigawatt of capacity

05:07:07.229 --> 05:07:11.799
for this winter uh when we need it the most uh during

05:07:11.810 --> 05:07:16.680
the peak hours before the sun rises. Uh So there's

05:07:16.689 --> 05:07:18.869
a lot of information here. This is available. So I

05:07:18.878 --> 05:07:21.668
just comment at the main points. Uh The problem we're

05:07:21.680 --> 05:07:25.569
trying to solve is the sport capacity limit of the

05:07:25.970 --> 05:07:27.458
PDU region. Uh

05:07:29.430 --> 05:07:36.939
It came from unlimited to 3.3 in August this year and

05:07:36.949 --> 05:07:39.549
that happened because of a solar power plant that came

05:07:39.560 --> 05:07:43.939
in online 500 Megawatt solar power plant which is expected

05:07:43.949 --> 05:07:50.049
to seed in February 2024. Uh The methodology that they

05:07:50.060 --> 05:07:55.149
use to calculate the GTC which is associated with all

05:07:55.159 --> 05:07:59.220
the capacities that's available, considers that all

05:07:59.229 --> 05:08:02.168
food capacity is going to be generating and available

05:08:02.529 --> 05:08:07.958
at all times for the whole year. And that's one of

05:08:07.970 --> 05:08:10.510
the reasons why with the interest of this solar power

05:08:10.519 --> 05:08:15.159
plant, the limits went down so much, right? So we had

05:08:15.168 --> 05:08:20.019
unlimited uh export, went down to 3.3. And the consequences

05:08:20.029 --> 05:08:23.290
of this is as I was saying, we are going to have

05:08:23.299 --> 05:08:28.109
two gigawatts restricted in the pale region. Uh And

05:08:28.779 --> 05:08:31.779
another thing that's related to the risks that we've

05:08:31.790 --> 05:08:38.600
been talking today is uh the months of the winter is

05:08:38.609 --> 05:08:41.529
the month that we have more generation available in

05:08:41.540 --> 05:08:44.779
the pend region, right? And specifically during the

05:08:44.790 --> 05:08:48.060
night, that's when the wind blows harder. So

05:08:50.069 --> 05:08:55.378
if we have a solution that can uh better represent

05:08:55.619 --> 05:08:59.979
the capacity of the generation uh during the day and

05:08:59.989 --> 05:09:03.689
during the night, then we could release some of these

05:09:03.699 --> 05:09:07.319
megawatts to the grid. And that's what we've been thinking

05:09:07.329 --> 05:09:12.128
about after we saw this uh reducing value. And in the

05:09:12.140 --> 05:09:17.149
next slide, I show the two solutions that have been

05:09:18.040 --> 05:09:22.060
uh uh been discussed. One of them has been worked with

05:09:22.069 --> 05:09:27.588
by ECO they call it the T set. Uh And the problem

05:09:27.600 --> 05:09:30.890
here is it's, it's a very good idea. Uh They would

05:09:30.899 --> 05:09:34.220
consider real time data and do an online calculation

05:09:34.229 --> 05:09:36.970
of the GTC. So you wouldn't be necessarily to consider

05:09:36.979 --> 05:09:41.729
full capacity as I was mentioning before. Uh the problem

05:09:41.739 --> 05:09:43.850
is this is hard to implement, especially for the behind

05:09:44.069 --> 05:09:46.829
the region where you have so much I BR S in the

05:09:46.838 --> 05:09:49.649
region. So it's a complex thing to model dynamically

05:09:49.729 --> 05:09:53.659
So this could take months or a year to implement. So

05:09:53.668 --> 05:09:57.979
uh our proposal is why don't we do a bridge solution

05:09:58.479 --> 05:10:03.529
while we are not ready to implement the T set? If what

05:10:03.540 --> 05:10:06.409
brought the limit down was the entrance of a solar

05:10:06.418 --> 05:10:10.958
power plant. If I take that, obviously, solar capacity

05:10:10.970 --> 05:10:13.799
is not available at night. So if I take that out of

05:10:13.810 --> 05:10:17.869
the simulation, I would go back to the previous unlimited

05:10:18.540 --> 05:10:22.510
GTC. Uh So that's basically what we are proposing.

05:10:22.519 --> 05:10:27.449
So to do a rerun of the study to confirm that we

05:10:27.458 --> 05:10:32.140
go back to the situation that we had before uh where

05:10:32.149 --> 05:10:36.140
the solar power plant wasn't online. And we believe

05:10:36.149 --> 05:10:40.878
that this solution have many benefits. One of them

05:10:40.890 --> 05:10:44.199
is that's really close to what's proposed to do to

05:10:44.208 --> 05:10:47.338
the T set. In the simplest way possible. The T set

05:10:47.350 --> 05:10:50.760
will do this for every 30 minutes online. We're doing

05:10:50.769 --> 05:10:53.810
we are proposing to do this only two times of the day

05:10:53.819 --> 05:10:58.310
for the whole year, right? Uh This could be implemented

05:10:58.319 --> 05:11:00.918
before the winter because you basically just need to

05:11:00.930 --> 05:11:04.409
rerun and make sure that everything is going to be

05:11:04.418 --> 05:11:07.600
safe in terms of operations and just implemented in

05:11:07.609 --> 05:11:12.079
real time, it delivers power when it's needed the most

05:11:12.149 --> 05:11:15.060
Since again, there's a lot of wind generation during

05:11:15.069 --> 05:11:19.540
the night and that's when the peak load is 6 a.m. uh

05:11:20.540 --> 05:11:25.329
in the winter, it adds additional one gigawatt of capacity

05:11:25.338 --> 05:11:30.338
without any costs, basically man hours to do the simulations

05:11:31.220 --> 05:11:35.628
and it could save up to $90 million in congestion savings

05:11:35.640 --> 05:11:39.109
annually. That's simulations we ran based on the past

05:11:39.119 --> 05:11:42.010
but that's what we suppose could be the savings for

05:11:42.019 --> 05:11:43.208
the next year as well.

05:11:45.029 --> 05:11:48.010
Yeah, and that's the, the suggestion that we could

05:11:48.019 --> 05:11:50.649
study this and see if we can implement this in the

05:11:50.659 --> 05:11:51.290
next month.

05:11:53.790 --> 05:11:57.239
Yeah. So I, I mean, this has been brought up, I guess

05:11:57.248 --> 05:12:00.829
fairly recently in the stakeholder process and we've

05:12:01.019 --> 05:12:04.040
been considering whether we can do it or not as with

05:12:04.049 --> 05:12:06.239
most things, it's not as easy as you think it would

05:12:06.248 --> 05:12:09.970
be. Uh And that we'd have to be very careful about

05:12:09.979 --> 05:12:14.208
uh how we step down the limit. So let's say the output

05:12:14.220 --> 05:12:16.998
of the units is really high, then we stepped it back

05:12:17.010 --> 05:12:19.989
in and when the sun, you know, before the sun comes

05:12:19.998 --> 05:12:23.899
up and you're having to scale all that down. And so

05:12:23.909 --> 05:12:27.220
we had, we can't violate that limit. So we'd have to

05:12:27.229 --> 05:12:31.010
watch how we, how we did that um And make sure we

05:12:31.019 --> 05:12:33.689
did it at the right time. And so there's, there's some

05:12:33.699 --> 05:12:36.760
procedural things like that. I mean, obviously, TS

05:12:36.869 --> 05:12:40.229
A is the right solution because it would do, it not

05:12:40.239 --> 05:12:43.708
would adjust the limits based on what is online all

05:12:43.720 --> 05:12:47.220
the time. We've actually had this, the, the, the thing

05:12:47.229 --> 05:12:50.229
that's holding us up is not as much anything within

05:12:50.279 --> 05:12:53.248
ERCOT as we still don't have all the models. And that's

05:12:53.260 --> 05:12:56.040
been a requirement. It's been referred to enforcement

05:12:56.359 --> 05:12:59.199
uh for, to get the rest of the models. And so there

05:12:59.208 --> 05:13:01.439
that's really the, the, the problem with getting it

05:13:01.449 --> 05:13:04.049
done now, it's not really the complexity. It's more

05:13:04.060 --> 05:13:06.958
the, we've got to get all that. All those TS A, the

05:13:07.199 --> 05:13:10.720
the generators provide PSSE models when they're going

05:13:10.729 --> 05:13:14.549
through the interconnection process. But we run this

05:13:14.859 --> 05:13:18.208
TS a simulator for in real time, the one that we're

05:13:18.220 --> 05:13:20.128
in, in real time. So we have to get the same kind

05:13:20.140 --> 05:13:24.109
of model that they already gave us in. Uh PSSE. We've

05:13:24.119 --> 05:13:27.869
got to get that where it's built for TS A and some

05:13:27.878 --> 05:13:31.260
of the generators still haven't given us those. Um

05:13:31.338 --> 05:13:35.088
Hey, Dan, just simple question. So if you were to overcome

05:13:35.119 --> 05:13:38.248
the technical analysis hurdles, clearly that are, that

05:13:38.260 --> 05:13:41.519
are present, do you agree that the magnitude of the

05:13:41.529 --> 05:13:47.140
stranded energy could be a gigawatt? I don't have those

05:13:47.149 --> 05:13:49.109
numbers in my, off the top of my head. I don't, I

05:13:49.119 --> 05:13:53.458
don't think it's, it, it, it went down from, uh I mean

05:13:53.470 --> 05:14:00.269
it was unlimited before. So it could be, it calculating

05:14:00.279 --> 05:14:02.430
limits is kind of like peeling the layer on an onion

05:14:02.439 --> 05:14:05.299
OK. So you pull off the outside layer and there may

05:14:05.310 --> 05:14:07.668
be another layer right underneath it that we haven't

05:14:07.680 --> 05:14:10.579
identified before. And so we, we'd have to look at

05:14:10.588 --> 05:14:12.989
that and I think that's one of the others, one of the

05:14:12.998 --> 05:14:15.159
other items on my list of things we have to look at

05:14:15.168 --> 05:14:18.269
There's that make it more complex than what you'd think

05:14:19.890 --> 05:14:23.649
but we're looking at it. I, I have one question and

05:14:23.659 --> 05:14:28.628
that's just that in accordance with this presentation

05:14:29.239 --> 05:14:33.918
the question would be why would you put a GTC in place

05:14:33.930 --> 05:14:39.939
for a plant that is not COD until 2024 and make, make

05:14:39.949 --> 05:14:42.998
that effective in 2023? Is that just timing of when

05:14:43.010 --> 05:14:47.760
you do these model runs or is that I don't but uh

05:14:47.769 --> 05:14:50.790
quarterly stability assessment. So, you know, if they're

05:14:50.799 --> 05:14:53.040
going to be online in this point in time, we have to

05:14:53.049 --> 05:14:56.119
we're doing that study uh months in advance, but it's

05:14:56.128 --> 05:15:00.359
also they synchronized to the grid. So they've got

05:15:00.369 --> 05:15:03.489
connect, they're putting in powers that what step of

05:15:03.498 --> 05:15:06.040
that interconnection process they're in that we talked

05:15:06.049 --> 05:15:11.128
about earlier. Um They just, if they're not in, in

05:15:11.529 --> 05:15:11.958
uh

05:15:13.918 --> 05:15:16.760
I guess I should just say, I don't know what their

05:15:16.769 --> 05:15:21.739
dates are. But um if under the assumption that they're

05:15:21.748 --> 05:15:27.579
coming on in, in say February of 2024 we would be doing

05:15:27.588 --> 05:15:33.220
the QS A well in advance for that. And um they may

05:15:33.229 --> 05:15:36.540
already be putting power on the grid and synchronized

05:15:39.409 --> 05:15:41.510
And so we have to limit based on the fact that they're

05:15:41.519 --> 05:15:43.909
they're, they're there and synchronized.

05:15:45.790 --> 05:15:50.180
I know that you all have looked at, you've studied

05:15:50.189 --> 05:15:53.739
you've, you've pushed for synchronous condensers on

05:15:53.748 --> 05:15:58.668
the West. Have you thought about synchronous condensers

05:15:58.680 --> 05:16:01.399
in the Panhandle for more stability reasons. There's

05:16:01.409 --> 05:16:04.699
already two up there. I thought there were stat coms

05:16:05.430 --> 05:16:08.439
they're synchronous condensers, right? Yeah, there's

05:16:08.479 --> 05:16:13.088
two on the panhandle and, but Woody, didn't you tell

05:16:13.100 --> 05:16:15.180
me that there were stat comps also that you kind of

05:16:16.418 --> 05:16:21.680
regretted putting in there that you would rather have

05:16:21.689 --> 05:16:23.619
more synchronous condensers,

05:16:25.519 --> 05:16:28.049
obviously long lines coming out of the panhandle

05:16:30.569 --> 05:16:33.140
stability issues. You explain what you said

05:16:35.668 --> 05:16:38.998
we have two synchronous convincer in the pan already

05:16:39.010 --> 05:16:42.668
Mhm. So I'm not sure about the other conversation.

05:16:42.680 --> 05:16:45.458
Maybe, maybe it was, maybe it was serious compensation

05:16:45.470 --> 05:16:47.979
I don't, I don't remember exactly what it was, but

05:16:47.989 --> 05:16:51.869
at one point in time, we had a discussion about could

05:16:51.878 --> 05:16:55.600
more transfer capacity happen if you've created more

05:16:55.609 --> 05:16:58.040
stability on those long lines coming out of the panhandle

05:16:58.049 --> 05:17:00.458
And you know, we think of synchronous condensers coming

05:17:00.470 --> 05:17:03.769
out of the west and do we think about synchronous condensers

05:17:03.779 --> 05:17:04.779
for those as well?

05:17:06.299 --> 05:17:08.958
I think we've have, those have always been in the toolbox

05:17:08.970 --> 05:17:10.600
It's always been something we've looked at. We've been

05:17:10.609 --> 05:17:13.619
actually put projects in place to have those installed

05:17:13.628 --> 05:17:16.310
and there are some there. Now, now as you have more

05:17:16.319 --> 05:17:18.899
generation get at it, we'll continue to look at that

05:17:19.878 --> 05:17:23.069
So it's a possibility. Yes. OK.

05:17:24.829 --> 05:17:26.248
I wasn't trying to put you on the spot.

05:17:29.510 --> 05:17:35.329
So I guess just one closing question is Dan. So um

05:17:35.779 --> 05:17:38.829
do you believe that y'all can evaluate whether you

05:17:38.838 --> 05:17:44.040
can run this calculation that um Omega proposed or

05:17:44.369 --> 05:17:47.989
to see if it's, if it's a limit you can lower or

05:17:47.998 --> 05:17:51.119
is it just a no because of the solar plant coming on

05:17:51.128 --> 05:17:52.609
Like I'm just trying to figure out what's the next

05:17:52.619 --> 05:17:54.729
step of anything on?

05:17:56.779 --> 05:18:00.628
Well, I guess one thing I'm trying to be, I don't want

05:18:00.640 --> 05:18:04.449
to commit to something um until we send out a market

05:18:04.458 --> 05:18:07.359
notice and those kind of things. So, I don't know really

05:18:07.369 --> 05:18:10.668
at this point is the answer. Um But we are looking

05:18:10.680 --> 05:18:13.720
at it. So we got 2.5 months to figure it out before

05:18:13.729 --> 05:18:17.189
we enter winter and the commission needs to follow

05:18:17.199 --> 05:18:20.909
up. It's a gig and it's a gig according to him. And

05:18:20.918 --> 05:18:24.680
we've got a legislative letter. So can I, can I just

05:18:24.689 --> 05:18:28.299
comment on the, the capacity just to make sure it's

05:18:28.310 --> 05:18:32.338
so the, the limit that's in place today is 3.3 gigs

05:18:32.350 --> 05:18:36.699
and the installed capacity is 4.2. So that's why it's

05:18:36.708 --> 05:18:37.399
one gigawatt.

05:18:39.489 --> 05:18:41.439
It's not complicated, man. No, I'm just saying that

05:18:41.449 --> 05:18:46.970
it's Yeah, gotta figure it out no more questions. Thank

05:18:46.979 --> 05:18:51.720
you, Dan. Thank you. Next panel is uh expectations

05:18:51.729 --> 05:18:55.359
for the winter and we will have Pete From a again regarding

05:18:55.369 --> 05:18:59.189
weather update and anything else you want us to say

05:19:01.588 --> 05:19:01.619
Ok.

05:19:03.659 --> 05:19:04.199
Ok,

05:19:06.579 --> 05:19:07.489
Pete Warton Eco.

05:19:09.248 --> 05:19:12.609
So, um I understand that we covered a lot of questions

05:19:12.619 --> 05:19:16.418
on the, the risk model for the Mora. So, um I'll, I'll

05:19:16.430 --> 05:19:18.838
review the winter weather outlook and then after that

05:19:19.208 --> 05:19:21.668
um we can get to the question about the, you know,

05:19:21.680 --> 05:19:24.208
the probabilities and I'm sure that you brought up

05:19:24.378 --> 05:19:26.378
and there may be any other questions about the model

05:19:26.390 --> 05:19:28.708
at that point, but I understand we want to try to make

05:19:28.720 --> 05:19:30.299
that more of an abbreviated session.

05:19:32.140 --> 05:19:37.519
So, uh on the slide here, uh the first statement uh

05:19:37.909 --> 05:19:43.220
very to the point, very unusual pattern. Um So again

05:19:43.229 --> 05:19:48.199
noting here El Nino and then uh very uh warm, you know

05:19:48.208 --> 05:19:52.180
ocean temperatures and things like that um are causing

05:19:52.189 --> 05:19:54.519
difficulties in terms of being able to do some pre

05:19:54.659 --> 05:19:57.838
early predictions at this point. So I think that the

05:19:57.850 --> 05:20:01.720
message is that um there's a lot of uncertainty at

05:20:01.729 --> 05:20:04.859
this point in time to do uh a weather forecast. And

05:20:04.869 --> 05:20:07.290
so our, our meteorologist recommends that uh you know

05:20:07.299 --> 05:20:10.729
we go to the no November release of the, the weather

05:20:10.739 --> 05:20:13.239
forecast and there should be a little bit more certainty

05:20:13.248 --> 05:20:16.549
around that. So, you know, that's kind of the main

05:20:16.560 --> 05:20:19.779
message here. Can you make sure your meteorologist

05:20:19.790 --> 05:20:22.060
provides a winter weather forecast at the December

05:20:22.069 --> 05:20:25.949
board meeting? I'm sorry, the December board meeting

05:20:25.970 --> 05:20:28.449
a weather forecast. Yeah, I understand. It's a little

05:20:28.458 --> 05:20:30.588
uncertain right now, but it would have been helpful

05:20:30.600 --> 05:20:33.119
to understand what he's seen through the NOA models

05:20:33.409 --> 05:20:35.600
and all the different modeling that ERCOT looks at

05:20:35.769 --> 05:20:37.560
Just to start getting a sense. Of course, there's a

05:20:37.569 --> 05:20:39.619
lot of uncertainty. So we still got some time, but

05:20:39.628 --> 05:20:42.199
I think it would be helpful to hear from the meteorologist

05:20:42.208 --> 05:20:47.189
in December, what he's seen going in, um to the winter

05:20:47.489 --> 05:20:48.979
I think it's critically important.

05:20:51.458 --> 05:20:55.799
Um So a couple of points here, uh in terms of the

05:20:55.810 --> 05:20:59.878
temperatures, uh the expectation is that uh they're

05:20:59.890 --> 05:21:03.470
gonna be below normal uh through most of Texas you'll

05:21:03.479 --> 05:21:06.299
see here on the map there. Uh The one towards the top

05:21:06.649 --> 05:21:09.579
uh you got a swath, uh that's the dark ray there that's

05:21:09.588 --> 05:21:12.918
um, considered to be low normal temperatures. And then

05:21:12.930 --> 05:21:15.269
on the east side of the system up in the northeast

05:21:15.279 --> 05:21:18.890
there, uh, you have basically near, near normal temperatures

05:21:19.239 --> 05:21:21.699
and then way down below there in, in Rio Grande Valley

05:21:21.708 --> 05:21:25.810
you've got uh well below normal temperatures. And,

05:21:25.819 --> 05:21:28.748
uh, again, one of the other points is, uh, it's uncommon

05:21:28.760 --> 05:21:32.128
to see that combination of, of low temperature and

05:21:32.140 --> 05:21:36.149
low precipitation for, for winters. Uh, and so here

05:21:36.159 --> 05:21:38.168
we're mentioning that there's only been three like

05:21:38.180 --> 05:21:42.439
that, uh, over about the last 20 years and then on

05:21:42.449 --> 05:21:45.399
the precipitation front, uh, again, it's, it's sort

05:21:45.409 --> 05:21:50.819
of a mixed bag. Um, the, uh, the map to the lower

05:21:50.829 --> 05:21:54.189
uh, right there, uh, below normal, you'll see that

05:21:54.199 --> 05:21:58.128
in, in North Texas there. Um, and then, uh, above normal

05:21:58.140 --> 05:22:00.189
down in the Rio Grande Valley there, it's kinda hard

05:22:00.199 --> 05:22:04.430
to see there, uh, in green there and then, uh, near

05:22:04.439 --> 05:22:07.579
normal, uh, you know, through the Austin San Antonio

05:22:07.588 --> 05:22:11.588
Houston area and then, uh, for the far west there,

05:22:11.600 --> 05:22:13.600
it's, you know, below normal precipitation.

05:22:16.049 --> 05:22:19.239
And then again, this was the statement I made this

05:22:19.248 --> 05:22:23.260
morning about, uh, the fact that you've got normal

05:22:23.390 --> 05:22:26.159
or, you know, higher than normal temperatures doesn't

05:22:26.168 --> 05:22:30.029
mean that you're gonna get, um, you know, less of a

05:22:30.040 --> 05:22:32.109
risk that you're gonna have like a severe winter storm

05:22:32.540 --> 05:22:36.239
So, again, that's something that, uh, uh, that our

05:22:36.248 --> 05:22:38.689
meteorologist cautions us all the time. Uh when we're

05:22:38.699 --> 05:22:40.930
talking about, you know, weather and the impacts on

05:22:41.100 --> 05:22:45.418
on peak load and things like that. So that is all I

05:22:45.430 --> 05:22:49.739
had to, I have to say about the uh the uh winter

05:22:49.748 --> 05:22:53.329
weather outlook and y'all have more um solar on the

05:22:53.338 --> 05:22:58.168
system. Um I know these are temperature driven. Um

05:22:58.619 --> 05:23:03.390
I is there a cloud model? I mean, something that helps

05:23:03.399 --> 05:23:05.829
us look at cloud cover because obviously we've got

05:23:05.838 --> 05:23:08.649
somewhat solar across the system that it's becoming

05:23:08.699 --> 05:23:13.668
more and more of a, you know, uh contingency, contingency

05:23:13.680 --> 05:23:19.019
Good work. Well, I I can speak about um the solar generation

05:23:19.029 --> 05:23:24.199
profiles that we use. So those are based on um you

05:23:24.208 --> 05:23:28.378
know, cli I'm not gonna be able to speak meteorological

05:23:28.390 --> 05:23:31.600
models. Uh but again, they look at look at climate

05:23:32.109 --> 05:23:36.600
and they do have uh you know, uh cloudiness uh cloud

05:23:36.609 --> 05:23:41.208
cover variables that go into that. So our vendor goes

05:23:41.220 --> 05:23:46.088
back to 1980 for each weather year, they get all the

05:23:46.100 --> 05:23:48.899
weather uh statistics from that year and feed it into

05:23:48.909 --> 05:23:52.299
a power conversion model. But that is considering cloudiness

05:23:52.310 --> 05:23:54.668
and a whole bunch of other, you know, factors that

05:23:54.680 --> 05:23:57.489
go into it. So that, that is considered in the profiles

05:24:02.350 --> 05:24:06.010
Um So unless there aren't any other questions and we

05:24:06.019 --> 05:24:09.588
could go on to uh uh the probability question that

05:24:09.600 --> 05:24:13.909
that you had. So what, what we've done in the past

05:24:14.060 --> 05:24:17.390
and this is the, the se a reports, seasonal asess of

05:24:17.399 --> 05:24:20.829
resource adequacy, what we would do, we would create

05:24:20.838 --> 05:24:26.458
scenarios and uh we would fix a value, for example

05:24:26.470 --> 05:24:29.149
Uh If we wanted to do a, let's say a high load

05:24:29.180 --> 05:24:32.229
forecast type of thing or high high load value, we

05:24:32.239 --> 05:24:36.338
would take like 1/90 percentile value. Uh That's just

05:24:36.350 --> 05:24:39.418
an example. And then let's say for wind output, we

05:24:39.430 --> 05:24:42.390
would have a really low value. So maybe it's like 1/5

05:24:42.399 --> 05:24:46.290
percentile. So we would focus on really the key risk

05:24:46.299 --> 05:24:49.958
variables, you know, for, for grid reliability and

05:24:49.970 --> 05:24:54.439
fix those values. The problem is uh we don't have a

05:24:54.449 --> 05:24:57.010
a likelihood that that set of conditions are going

05:24:57.019 --> 05:25:01.208
to occur or ones that are similar to that. So what

05:25:01.220 --> 05:25:03.510
the risk model allows you to do is to come up with

05:25:03.519 --> 05:25:07.290
those probabilities or likelihood that a particular

05:25:07.299 --> 05:25:10.659
set of conditions are going to occur. And then most

05:25:10.668 --> 05:25:14.220
importantly is it, it generates, you know, basically

05:25:14.229 --> 05:25:17.970
a universe of outcomes, 10,000 runs uh that the model

05:25:17.979 --> 05:25:21.748
is set up to do and with all those combinations and

05:25:21.760 --> 05:25:24.378
you know, probabilities associated with each of those

05:25:24.390 --> 05:25:28.970
outcomes like, you know, uh outages and wind solar

05:25:29.029 --> 05:25:32.338
uh things like that. Then you're able to tell how many

05:25:32.350 --> 05:25:37.149
of those outcomes um out of that 10,000 population

05:25:37.159 --> 05:25:40.168
how many of those are below some sort of risk threshold

05:25:40.180 --> 05:25:43.649
value. And, and we're using the ee a, you know, trigger

05:25:43.659 --> 05:25:46.760
as the risk thresholds. So that's not something you

05:25:46.769 --> 05:25:50.430
could do uh with the old se a report, you are able

05:25:50.439 --> 05:25:53.720
to do that with this new model. And then also importantly

05:25:53.729 --> 05:25:57.829
is that uh you can account for the different relationships

05:25:57.838 --> 05:26:01.199
between different variables, you know, co correlations

05:26:01.208 --> 05:26:04.659
between probability distributions. You know, for example

05:26:05.100 --> 05:26:07.829
uh you have low temperatures negatively, you know,

05:26:07.838 --> 05:26:11.069
correlated with load. So that's something that's built

05:26:11.079 --> 05:26:14.439
into the mop. Uh and similarly low temperatures are

05:26:14.449 --> 05:26:18.549
are uh you know, uh correlated with uh high uh outages

05:26:18.560 --> 05:26:21.189
weather related outages. So that type of thing you

05:26:21.199 --> 05:26:24.899
can't do in a normal ce a type report, but you can

05:26:24.909 --> 05:26:27.720
do that in the model that we have to support the mora

05:26:28.290 --> 05:26:32.939
So hopefully that helps. I think I'm remembering that

05:26:32.949 --> 05:26:37.449
you incorporated the weatherization into, I guess this

05:26:37.458 --> 05:26:39.958
most recent model on the

05:26:42.350 --> 05:26:45.529
and then one other point is, uh uh you know, Commissioner

05:26:45.540 --> 05:26:49.659
McAdams, you, you want to see a 24 hour more report

05:26:49.668 --> 05:26:53.609
instead of just the, you know, uh the morning and uh

05:26:53.619 --> 05:26:56.519
early evening hours. So, yeah, you will see a full

05:26:56.529 --> 05:27:00.409
24 hour report. Ok, perfect.

05:27:02.119 --> 05:27:06.019
Any more questions for Pete? No, thank you so much

05:27:06.029 --> 05:27:09.260
Thank you. So we ended this topic. So it's the time

05:27:09.269 --> 05:27:14.168
for you to discuss and uh wrap it up before we give

05:27:14.180 --> 05:27:17.649
it to ERCOT for directly. So how long time do you wanna

05:27:17.680 --> 05:27:21.949
take? So just any additional discussion on any of the

05:27:21.958 --> 05:27:24.720
items we've had so far, although we've been discussing

05:27:24.729 --> 05:27:26.378
them right along, so we might be good.

05:27:28.378 --> 05:27:32.899
I, I think that the market is eager to hear from ERCOT

05:27:32.909 --> 05:27:36.088
in terms of answering questions about the RP madam

05:27:36.100 --> 05:27:38.189
chair. I have nothing further at this time.

05:27:42.029 --> 05:27:47.180
Ok. So um now CT is scheduled to present on their RP

05:27:47.470 --> 05:27:51.260
for contracts for capacity section four of STAS agenda

05:27:51.659 --> 05:27:55.159
We'll take a few moments just to transition and have

05:27:55.168 --> 05:27:56.579
URCO come up to the table.

05:27:59.290 --> 05:27:59.310
Yeah,

05:28:08.310 --> 05:28:11.729
why, why don't we go ahead and get started? Um So I'm

05:28:11.739 --> 05:28:15.199
gonna open us up um Pablo Vegas uh with uh the uh

05:28:15.378 --> 05:28:18.109
RCAT. I've got up here, the team, a bunch of folks

05:28:18.119 --> 05:28:22.279
from ERCOT that are ready to um talk about and explain

05:28:22.290 --> 05:28:26.729
kind of the overall RP for capacity that we um issued

05:28:27.010 --> 05:28:31.159
um a couple of weeks ago. And the purpose today is

05:28:31.168 --> 05:28:33.220
to, you know, kind of explain the overview of what

05:28:33.229 --> 05:28:35.329
we're trying to accomplish with this and then answer

05:28:35.338 --> 05:28:38.060
questions and make sure that uh those that are interested

05:28:38.069 --> 05:28:40.359
in, in uh participating in this, have a good understanding

05:28:40.369 --> 05:28:43.060
of how it's gonna work so that we can um get good

05:28:43.069 --> 05:28:45.458
submissions in and evaluate them and, and hopefully

05:28:45.659 --> 05:28:47.878
improve the reliability this winter as a result of

05:28:47.890 --> 05:28:52.140
this. So, um what I'd like to do is I'm gonna give

05:28:52.149 --> 05:28:54.790
a quick overview of kind of the drivers here. And so

05:28:55.199 --> 05:28:58.668
overall, we, we uh put forth an RP filler capacity

05:28:58.680 --> 05:29:02.878
for 3000 incremental megawatts of either supply or

05:29:02.890 --> 05:29:07.269
demand response. And this was really the, the driven

05:29:07.279 --> 05:29:09.378
from the fact that as we went through the summer and

05:29:09.390 --> 05:29:11.489
we saw the significant increase in demand, we started

05:29:11.498 --> 05:29:14.769
to begin thinking right away about the winter and recognizing

05:29:14.779 --> 05:29:19.310
the fact that in the summer time, we have a very different

05:29:19.319 --> 05:29:21.899
um you know, kind of supply portfolio and risk and

05:29:21.909 --> 05:29:25.369
risk portfolio than we do in the winter. Um The peaks

05:29:25.378 --> 05:29:27.769
that we saw during the summer were, were, were managed

05:29:27.779 --> 05:29:30.649
very well by a strong performing fleet across the board

05:29:30.659 --> 05:29:32.838
but also the incremental solar that has been developed

05:29:32.850 --> 05:29:35.310
since the prior summer. And we all know that in the

05:29:35.319 --> 05:29:37.998
winter time, the peaks tend to be early in the morning

05:29:38.010 --> 05:29:40.790
before the sun comes up or later in the evening after

05:29:40.799 --> 05:29:43.180
it goes down. And so we weren't going to get the benefit

05:29:43.189 --> 05:29:45.529
of the incremental solar resources that we saw this

05:29:45.540 --> 05:29:48.909
summer. And so starting to think through kind of, you

05:29:48.918 --> 05:29:52.628
know, the the potential risk. We we as and at the same

05:29:52.640 --> 05:29:55.958
time, we were shifting to the new Mora uh concept,

05:29:55.970 --> 05:29:58.819
which is the monthly resource Adequacy report, which

05:29:58.829 --> 05:30:02.060
is replacing the seasonal adequacy report. And so as

05:30:02.069 --> 05:30:04.338
we started to run the probabilities for the winter

05:30:04.350 --> 05:30:08.958
with the new Mora, um we started to see uh a higher

05:30:08.970 --> 05:30:12.069
risk profile emerging this winter that led us to start

05:30:12.079 --> 05:30:14.470
thinking about what tools do we have in the toolbox

05:30:14.479 --> 05:30:17.369
in order to deal with the potential incremental risk

05:30:17.779 --> 05:30:21.510
Um, what we did is we chose a weather event that was

05:30:21.519 --> 05:30:24.619
similar to last year's winter storm Elliott as kind

05:30:24.628 --> 05:30:27.668
of the baseline that for an extreme weather event that

05:30:27.680 --> 05:30:30.529
we wanted to be able to manage through with a reasonable

05:30:30.540 --> 05:30:34.220
risk outcome. We chose the winter storm Elliott storm

05:30:34.399 --> 05:30:37.640
because as we looked over the last 14 years or so,

05:30:37.649 --> 05:30:40.458
that's been, there's been approximately four storms

05:30:40.569 --> 05:30:43.609
that have been similar or in some cases worse than

05:30:43.619 --> 05:30:45.850
winter storm Elliott. And so we thought that was a

05:30:45.859 --> 05:30:49.600
reasonable proxy of an extreme weather event to consider

05:30:49.609 --> 05:30:53.970
for um for AAA possibility of some of something occurring

05:30:53.979 --> 05:30:56.739
and wanting to have a system that could withstand and

05:30:56.748 --> 05:30:59.799
and support uh all of the needs during an event like

05:30:59.810 --> 05:31:03.729
that. And so as we ran the MO report with that model

05:31:03.739 --> 05:31:07.549
and with the current demand forecast, we saw the elevated

05:31:07.560 --> 05:31:12.279
risk of an ee a event moving up to about 20% and

05:31:12.290 --> 05:31:14.579
that is definitely higher than what we had seen in

05:31:14.588 --> 05:31:18.409
prior years for, uh for the potential scenarios. And

05:31:18.418 --> 05:31:21.290
so what we, we, we looked at, you know, the way we

05:31:21.299 --> 05:31:26.378
model risk for NC, we tend we use a 10% threshold with

05:31:26.390 --> 05:31:30.140
our nerc winter risk assessments. If it's above 10%

05:31:30.149 --> 05:31:32.779
we te we characterize that as an elevated risk. If

05:31:32.790 --> 05:31:35.729
it's below 10% we, we characterize it as a low risk

05:31:36.159 --> 05:31:38.668
And so what we wanted to do is um we, we back

05:31:38.680 --> 05:31:41.439
salve into the 3000 megawatts by saying, ok, how many

05:31:41.449 --> 05:31:44.489
megawatts incremental would we need in order to get

05:31:44.498 --> 05:31:48.189
that risk profile down below a 10% under a winter storm

05:31:48.199 --> 05:31:50.779
Elliott type of event this winter. And so that's how

05:31:50.790 --> 05:31:55.458
the 3000 megawatts came out. And so, um that's the

05:31:55.470 --> 05:31:57.729
base, that's the basic drivers of what we're trying

05:31:57.739 --> 05:32:00.449
to do and, and basically what, you know, led to the

05:32:00.458 --> 05:32:04.029
issuance of the RP for capacity. So let me turn it

05:32:04.040 --> 05:32:06.470
over to Woody who's gonna take us through the next

05:32:06.479 --> 05:32:08.859
slide and kind of a little bit more on the probabilities

05:32:10.838 --> 05:32:14.579
Yeah. So the uh the analysis that we use is very similar

05:32:14.588 --> 05:32:18.109
to the Mora analysis. It uses a Monte Carlo set of

05:32:18.119 --> 05:32:22.878
runs a probabilistic analysis. Um Look over my shoulder

05:32:22.890 --> 05:32:24.290
here. Oh, ok.

05:32:26.989 --> 05:32:29.890
So it does account for the demand growth that we experienced

05:32:29.899 --> 05:32:34.040
in 2023. So as we sat there and we saw the 85,000

05:32:34.049 --> 05:32:36.970
Megawatt summer load that's also factored into this

05:32:36.979 --> 05:32:41.229
We, we see that load growth in this model. Um The highest

05:32:41.239 --> 05:32:46.409
risk hours for the summer obviously are like eight

05:32:46.418 --> 05:32:51.549
pm after, after the sunset. Um That's different in

05:32:51.560 --> 05:32:53.560
the winter though. And that's really what causes a

05:32:53.569 --> 05:32:57.299
lot of this risk. So in the winter, the highest risk

05:32:57.310 --> 05:32:59.810
hours are gonna be before the sun comes up and after

05:32:59.819 --> 05:33:02.869
the sun goes down. So that moves the highest risk hour

05:33:02.878 --> 05:33:07.659
to like 8 a.m. And so it was um if you have

05:33:08.560 --> 05:33:10.229
and Elliott like storm

05:33:11.949 --> 05:33:16.729
this winter, that risk with the current mix of resources

05:33:16.739 --> 05:33:22.248
was about about 20% 20% chance of having an ee a event

05:33:22.878 --> 05:33:26.338
So based on that, based on that risk, that elevated

05:33:26.350 --> 05:33:29.299
risk, that's why we're asking for this. So that's really

05:33:29.310 --> 05:33:34.260
how this uh this uh analysis was done. It's very, very

05:33:34.269 --> 05:33:36.560
similar to what we do with the tomorrow. It will be

05:33:36.569 --> 05:33:39.378
very similar to what you see every month as we go forward

05:33:39.390 --> 05:33:43.269
this probabilistic analysis. So I don't any, any questions

05:33:43.279 --> 05:33:45.079
about how the analysis was put together.

05:33:51.220 --> 05:33:51.799
All right.

05:33:56.878 --> 05:33:58.998
So I, I'll talk to, I'll talk to this one on the

05:33:59.010 --> 05:34:01.540
procurement schedule. And so here we are today on uh

05:34:01.549 --> 05:34:05.409
October 20th, the workshop. Uh So Monday, we will come

05:34:05.418 --> 05:34:08.549
out with red lines on what we're changing with the

05:34:08.560 --> 05:34:12.079
RFP and the governing documents including some new

05:34:12.088 --> 05:34:15.119
forms. I think this is where, but I mean, I'm sure

05:34:15.128 --> 05:34:19.199
everybody can hear me. Um We'll also probably tweak

05:34:19.208 --> 05:34:22.019
some of the schedule too so that everybody has a little

05:34:22.029 --> 05:34:25.699
bit more time to submit the proposals. Uh Right now

05:34:25.708 --> 05:34:27.899
it looks like it's, it's only two weeks from when we

05:34:27.909 --> 05:34:32.350
come out with the uh the final RP on October 23rd,

05:34:32.359 --> 05:34:34.859
which is Monday, we'll probably give a couple more

05:34:34.869 --> 05:34:38.510
days for everyone to be looking at the RFP changes

05:34:38.619 --> 05:34:41.720
and make those decisions. So I would expect that proposal

05:34:41.729 --> 05:34:44.299
deadline to shift a little bit. Ultimately, the rest

05:34:44.310 --> 05:34:46.799
of the schedule will, will still be in line with our

05:34:46.810 --> 05:34:50.399
target service dates of December 1st through January

05:34:50.409 --> 05:34:54.979
9th for those that submit offers and have the capability

05:34:54.989 --> 05:34:57.998
to be available during that window. Of course, January

05:34:58.010 --> 05:35:00.769
9th would be the outside of that window where anything

05:35:00.779 --> 05:35:03.350
past January 9th that could be available, we're not

05:35:03.359 --> 05:35:06.668
going to consider. So this is the the current timeline

05:35:06.680 --> 05:35:09.338
but it will be adjusted on Monday when we come out

05:35:09.350 --> 05:35:11.549
with the red lines. And of course, all this will be

05:35:11.560 --> 05:35:14.819
posted on ica's website under the procurement page

05:35:14.829 --> 05:35:17.079
where we've been putting everything we'll send out

05:35:17.088 --> 05:35:19.418
a market notice like we've been doing, keeping everybody

05:35:19.430 --> 05:35:23.939
apprised. So as we go through the remaining slides

05:35:24.220 --> 05:35:28.790
what we've done is taken the 130 plus questions that

05:35:28.799 --> 05:35:32.029
were very helpful and made us think through some of

05:35:32.040 --> 05:35:35.109
the additional changes with the original documents

05:35:35.119 --> 05:35:37.819
that came out and we'll start to highlight the key

05:35:37.829 --> 05:35:40.989
details of the RP that you'll be seeing on Monday.

05:35:41.199 --> 05:35:43.439
And then we can talk about some of the responses to

05:35:43.449 --> 05:35:46.010
the questions that we've identified as really kind

05:35:46.019 --> 05:35:49.010
of the hot topics on the remaining slides. And then

05:35:49.019 --> 05:35:51.949
we also filed this with the commission along with all

05:35:51.958 --> 05:35:55.899
of our responses that we submitted on Wednesday and

05:35:55.909 --> 05:35:59.329
we can facilitate a discussion that way. So I'll turn

05:35:59.338 --> 05:36:02.269
it over to uh I think DaVita, were you gonna walk through

05:36:02.279 --> 05:36:03.529
this first? This slide?

05:36:06.529 --> 05:36:08.260
Happy to do so. Thank you, Chad.

05:36:10.899 --> 05:36:14.319
So, in this procurement, we're seeking to procure capacity

05:36:14.329 --> 05:36:20.319
from generation resources, E SR S which includes distributed

05:36:20.329 --> 05:36:25.199
E SR S and providers of demand response in the market

05:36:25.208 --> 05:36:29.479
notice. We included types of um resources that we thought

05:36:29.489 --> 05:36:32.390
might be eligible to provide the service that's based

05:36:32.399 --> 05:36:35.470
on our requirement and the protocols. Um We've since

05:36:35.479 --> 05:36:38.510
also modified some of the requirements regarding demand

05:36:38.519 --> 05:36:42.479
response in response to questions. So the eligible

05:36:42.489 --> 05:36:45.579
generation resources are mothballed, dispatchable generation

05:36:45.588 --> 05:36:48.458
resources, seasonally mothballed, dispatchable generation

05:36:48.470 --> 05:36:51.540
resources, decommissioned, dispatchable generation

05:36:51.549 --> 05:36:54.739
resources and those dispatchable generation resources

05:36:54.748 --> 05:36:57.869
that are currently um in the interconnection queue

05:36:58.128 --> 05:37:00.739
um with specified synchronization dates which will

05:37:00.748 --> 05:37:04.199
be in in the RP and the governing document such that

05:37:04.208 --> 05:37:07.779
their interconnection could be accelerated um subject

05:37:07.790 --> 05:37:10.100
to meeting all of our interconnection requirements

05:37:10.970 --> 05:37:13.890
for we're, we're also going to create a new separate

05:37:13.899 --> 05:37:17.229
category specifically for E SR S given their unique

05:37:17.239 --> 05:37:21.829
um characteristics um and potential E SR S in the queue

05:37:21.838 --> 05:37:24.430
with specified dates that can be accelerated will also

05:37:24.439 --> 05:37:27.588
be eligible to offer in. And then finally, we have

05:37:27.600 --> 05:37:32.180
eligible demand response providers. Um Those include

05:37:32.189 --> 05:37:35.019
customers, individual customers or aggregations of

05:37:35.029 --> 05:37:38.319
customers, not limited to any specific load zones or

05:37:38.329 --> 05:37:41.659
regions um with peak demand response capability that

05:37:41.668 --> 05:37:45.168
was not price responsive over the last year and have

05:37:45.180 --> 05:37:47.998
not participated in an existing demand response or

05:37:48.010 --> 05:37:51.350
load management program in the past two years. And

05:37:51.359 --> 05:37:53.708
we also have uh another requirement that they have

05:37:53.720 --> 05:37:57.140
to have been energized since May 1 2023. And that's

05:37:57.149 --> 05:37:59.970
because we need to have the ability to establish baselines

05:37:59.979 --> 05:38:01.529
in order to assess performance.

05:38:03.600 --> 05:38:06.799
Um the service start dates. As as chad mentioned, we

05:38:06.810 --> 05:38:09.619
actually have a range of service start dates and recognition

05:38:09.628 --> 05:38:12.659
that there's um a lot that folks need to do in order

05:38:12.668 --> 05:38:15.918
to get ready to provide the service. Um And the service

05:38:15.930 --> 05:38:20.299
end date generally is February 29th, 2024. With the

05:38:20.310 --> 05:38:23.159
exception of those for whom we're accelerating in our

05:38:23.168 --> 05:38:25.899
connection. And for those, we'll look at what you otherwise

05:38:25.909 --> 05:38:29.128
would have had for your um um period in which you are

05:38:29.140 --> 05:38:31.909
going to be entering operations so that we aren't compensating

05:38:31.918 --> 05:38:34.269
you for um service that you already would have been

05:38:34.279 --> 05:38:37.329
providing um pre-existing acceleration.

05:38:39.029 --> 05:38:41.260
So maybe we can expand upon that point right there

05:38:41.269 --> 05:38:44.299
Just so everybody understands as an example, I don't

05:38:44.310 --> 05:38:46.290
know if Nathan, you wanna take a shot at that.

05:38:48.319 --> 05:38:50.819
Yeah, an example of acceleration of a generation resource

05:38:50.829 --> 05:38:54.560
Yeah. So for example, if you have a synchronization

05:38:54.569 --> 05:38:59.859
date, that is February 15th, for example, um you could

05:38:59.869 --> 05:39:04.220
accelerate that to January 15th, let's say. And so

05:39:04.229 --> 05:39:08.049
the contract would apply from January 15th through

05:39:08.060 --> 05:39:11.779
February 15th, not through the end of February as would

05:39:11.790 --> 05:39:15.100
be the case for resources that are not accelerating

05:39:15.748 --> 05:39:19.588
So that's an example there. Yeah. And I think actually

05:39:19.600 --> 05:39:23.100
it would have to be January 9th instead of January

05:39:23.109 --> 05:39:25.439
15th. I'm sorry. That's right. Actually January 9th

05:39:25.449 --> 05:39:28.269
is the last start date. That's a more accurate example

05:39:29.239 --> 05:39:31.338
Does that make sense? Anybody having questions? Yes

05:39:32.040 --> 05:39:34.180
And I don't know if we want to pass the mic around

05:39:34.189 --> 05:39:37.998
or, or just talk about. Well, except there's uh it's

05:39:38.010 --> 05:39:41.909
being on um webcast. So I think we will have to pass

05:39:41.918 --> 05:39:42.579
the mic around.

05:39:46.338 --> 05:39:46.659
Ok. Fine.

05:39:48.859 --> 05:39:52.579
Uh manu with hot energy Network two questions. First

05:39:52.588 --> 05:39:54.790
question, does the eligible generation resources, does

05:39:54.799 --> 05:39:56.359
that include D GR S as well

05:39:58.069 --> 05:40:00.310
that are going through the process? The interconnection

05:40:00.319 --> 05:40:00.829
process?

05:40:02.540 --> 05:40:05.760
Yes, it would. OK. Uh And, and the second question

05:40:05.769 --> 05:40:10.498
is uh for the customers, for those C and I customers

05:40:10.588 --> 05:40:13.720
that may have backup generation, would they be eligible

05:40:13.729 --> 05:40:16.699
to participate? Uh Is there a mechanism that would

05:40:16.708 --> 05:40:20.560
allow them to participate through this RP process that

05:40:20.569 --> 05:40:23.418
would that do not generally use their backup generation

05:40:23.430 --> 05:40:26.739
for price responsiveness just for emergency purposes

05:40:30.049 --> 05:40:32.519
Yeah, so yes, there is. That's right. There is going

05:40:32.529 --> 05:40:38.140
to be a, a price responsiveness test for any sort of

05:40:38.748 --> 05:40:41.128
load that could be offered in that test is going to

05:40:41.140 --> 05:40:43.930
be changed a bit from what was in the original proposal

05:40:44.350 --> 05:40:47.649
It's going to be looking at high priced periods of

05:40:47.659 --> 05:40:52.869
time since last December and if a given load has exhibited

05:40:52.878 --> 05:40:57.510
price responsive behavior, um, during, um, I think

05:40:57.519 --> 05:41:02.229
the test is more than five, more than 25% of the high

05:41:02.239 --> 05:41:05.600
price days with an average load reduction greater than

05:41:05.609 --> 05:41:10.019
5% on those days. Um, then, uh they'll be deemed to

05:41:10.029 --> 05:41:12.680
be price responsive. So if you've got backup generation

05:41:12.890 --> 05:41:16.979
that is creating that price responsive demand, then

05:41:16.989 --> 05:41:20.909
you know, that's going to have to correlate um in a

05:41:20.918 --> 05:41:23.739
way that that doesn't result in you being deemed price

05:41:23.748 --> 05:41:27.769
responsive, but you get, you get credit for that, that

05:41:27.779 --> 05:41:28.100
you're all

05:41:30.199 --> 05:41:31.010
not for any ex.

05:41:32.890 --> 05:41:34.689
Ok. Ok. That's right.

05:41:38.088 --> 05:41:38.790
Thank you.

05:41:41.119 --> 05:41:44.619
Um This is really a question that maybe I know GSM

05:41:44.628 --> 05:41:47.609
already had but you, you have a provision there. Oh

05:41:47.619 --> 05:41:51.498
Cyrus Cyrus Reed S Club, you have a provision there

05:41:51.510 --> 05:41:55.290
saying if somebody has participated in a pre-existing

05:41:55.299 --> 05:41:57.369
demand response program the last two years, they, they're

05:41:57.378 --> 05:42:01.458
not eligible. Have you considered looking at whether

05:42:01.470 --> 05:42:04.299
that program was more of a summer program? And, and

05:42:04.310 --> 05:42:06.838
this is a winter, is that something that you would

05:42:06.850 --> 05:42:10.819
consider changing or you said on those two years? Given

05:42:10.829 --> 05:42:12.819
there are lots of people who have participated in summer

05:42:12.829 --> 05:42:15.859
programs, but this is a different kind of program.

05:42:18.970 --> 05:42:22.890
Go ahead. Give you, well, well, I wasn't involved in

05:42:22.899 --> 05:42:25.998
every single uh discussion, but I think the decision

05:42:26.010 --> 05:42:28.989
was that, that if you have been in programs and we

05:42:28.998 --> 05:42:31.569
had these other, the summer programs like the T DS

05:42:31.579 --> 05:42:34.909
P programs that are now winter programs that you would

05:42:34.918 --> 05:42:37.329
be incentivized to go ahead and continue to participate

05:42:37.338 --> 05:42:40.998
in those programs for this winter as well. So the capacities

05:42:41.168 --> 05:42:44.310
already can be. Yeah. But what if you were, what if

05:42:44.319 --> 05:42:47.878
you were in the market in a summer program? And this

05:42:47.890 --> 05:42:50.560
is a new opportunity in winter? So you weren't in a

05:42:50.569 --> 05:42:53.569
T DS P A paid for ratepayers. You were in a, a

05:42:53.689 --> 05:42:57.458
rep program or another program. So you couldn't, you

05:42:57.579 --> 05:43:00.338
you're saying you couldn't participate in this. That's

05:43:00.350 --> 05:43:02.949
what we're, that's what we're saying. Yes. If you have

05:43:02.958 --> 05:43:06.248
you, you're not gonna be able to participate in this

05:43:06.430 --> 05:43:08.918
You were expecting that there are going to be these

05:43:08.930 --> 05:43:11.799
other rep programs out there that you could very well

05:43:11.810 --> 05:43:15.588
be able to participate. Ok, I have another question

05:43:15.600 --> 05:43:17.779
that I, I should have asked earlier. Maybe it's for

05:43:17.998 --> 05:43:19.168
Pablo, um,

05:43:20.859 --> 05:43:25.739
this decision and this process is a new one. Will ERCOT

05:43:25.748 --> 05:43:30.979
be considering filing some kind of operating guide

05:43:30.989 --> 05:43:33.159
in the future? Can we expect that the same process

05:43:33.168 --> 05:43:38.790
is going to happen every summer and winter on the decision

05:43:38.799 --> 05:43:41.930
about the, the 10% probability or will there be some

05:43:41.939 --> 05:43:45.439
sort of filing of the market and the loads that pay

05:43:45.449 --> 05:43:48.790
for it? No, this is the process you're gonna use going

05:43:48.799 --> 05:43:52.119
forward or is this sort of a one time deal?

05:43:56.439 --> 05:43:56.470
Ok.

05:43:58.220 --> 05:44:03.299
Is this act, um, first off. I do, I don't think we

05:44:03.310 --> 05:44:05.628
expect this to be an every season type of an issue

05:44:05.640 --> 05:44:08.040
but we're always going to be evaluating the risk in

05:44:08.049 --> 05:44:11.128
the upcoming months. That's part of what the mo process

05:44:11.140 --> 05:44:15.168
is intended to do. And so if we are, I think following

05:44:15.180 --> 05:44:17.739
this process, we're going to learn a lot in terms of

05:44:17.748 --> 05:44:20.399
what's available, what's possible with the capacity

05:44:20.409 --> 05:44:24.350
type of a process like this. And I think we'll um probably

05:44:24.359 --> 05:44:27.338
implement some improvements and changes to this process

05:44:27.350 --> 05:44:29.199
if we were going to use it again or leverage it next

05:44:29.208 --> 05:44:32.579
winter as an example and how that gets done formally

05:44:32.588 --> 05:44:35.699
I'll let Chad, you know opine on that, but we're always

05:44:35.708 --> 05:44:38.399
going to be looking at the next couple of months ahead

05:44:38.409 --> 05:44:41.149
as part of this mor reporting and if we see something

05:44:41.159 --> 05:44:42.970
that looks very troubling, we're going to have to respond

05:44:42.979 --> 05:44:43.260
to it.

05:44:46.189 --> 05:44:48.519
So I imagine that Kathy Webb King is gonna have a follow

05:44:48.529 --> 05:44:50.708
up question to what you just said, which we would share

05:44:50.720 --> 05:44:54.180
her follow up question and on this. Oh, sorry Christina

05:44:54.189 --> 05:44:57.338
Rollins for NRG. Um I just had another question kind

05:44:57.350 --> 05:44:59.208
of to follow up on what Cyrus was saying about the

05:44:59.220 --> 05:45:02.680
summer only programs. I think you will find for a lot

05:45:02.689 --> 05:45:06.239
of a lot of larger customers, they won't necessarily

05:45:06.409 --> 05:45:10.040
be participating in a TDU winter load management program

05:45:10.359 --> 05:45:15.859
Um And so you might be excluding potential candidates

05:45:15.869 --> 05:45:21.180
for your 3000 Megawatt RP if you say it's summer only

05:45:21.470 --> 05:45:25.229
Um So that's something that maybe would be worth discussing

05:45:25.510 --> 05:45:28.409
Um But my other question is, and Katie might have a

05:45:28.418 --> 05:45:30.899
follow up on that, but I'm just trying to interpret

05:45:30.918 --> 05:45:33.088
here. She's saying, like you said, you're expecting

05:45:33.168 --> 05:45:35.918
them to participate in the winner version of the TSP

05:45:36.040 --> 05:45:39.199
programs if they, yeah, they have that.

05:45:42.470 --> 05:45:44.510
Yeah. So if the, I think Katie was saying is that if

05:45:44.519 --> 05:45:47.220
the premise for saying you couldn't participate, because

05:45:47.229 --> 05:45:49.449
the assumption was that they were going to be in the

05:45:49.458 --> 05:45:52.088
TDU programs in the winter, that's why you wouldn't

05:45:52.100 --> 05:45:55.399
have them in the, in, in this program. Um If that's

05:45:55.409 --> 05:45:58.010
actually not the case, then maybe that gets removed

05:45:58.019 --> 05:46:03.989
as a precondition. OK. The, the whole concept was we

05:46:03.998 --> 05:46:10.060
didn't want to try to set uh loads to move from a

05:46:10.069 --> 05:46:14.199
program that they've already shown they've been interested

05:46:14.208 --> 05:46:19.100
in participating in, uh We'll, we'll have customers

05:46:19.109 --> 05:46:22.970
that are not in those TDU programs, that the reason

05:46:22.979 --> 05:46:25.560
why they would be excluded is the summer restrictions

05:46:25.569 --> 05:46:28.829
So that, that would potentially open up candidates

05:46:28.838 --> 05:46:32.119
for um participation. So,

05:46:34.409 --> 05:46:38.029
so I mean, maybe that's something to consider. But

05:46:38.040 --> 05:46:40.529
one thing that may also play into that is the price

05:46:40.540 --> 05:46:43.588
responsiveness test because if they've, you know, demonstrated

05:46:43.600 --> 05:46:46.579
that they weren't there during these high price intervals

05:46:46.588 --> 05:46:48.819
right, then they may already be excluded for that reason

05:46:48.989 --> 05:46:51.489
by virtue of that participation in the summer program

05:46:51.680 --> 05:46:54.010
that price response in this inquiry is going to look

05:46:54.019 --> 05:46:57.909
at both summer and winter, you know, movement. So it

05:46:57.918 --> 05:46:59.699
could well be that that becomes a non issue for some

05:46:59.708 --> 05:47:02.649
of them, but maybe something worth worth considering

05:47:02.659 --> 05:47:04.229
here over the weekend as we finalize this

05:47:07.220 --> 05:47:10.239
Emily Jolly with LCRA, I wanna go back to that, that

05:47:10.248 --> 05:47:13.949
price responsiveness verification um process that you're

05:47:13.958 --> 05:47:17.418
describing Nathan. Um how transparent is that going

05:47:17.430 --> 05:47:20.949
to be? Um What sorts of verification are you going

05:47:20.958 --> 05:47:23.890
to engage in? Can you tell us more about that? Is there

05:47:23.899 --> 05:47:27.149
gonna be communication with that entities? LSE for

05:47:27.159 --> 05:47:27.838
example,

05:47:30.739 --> 05:47:32.479
Mark, I'm not sure if you know the particulars of that

05:47:32.489 --> 05:47:37.470
I, yeah, we're just gonna be, but as far of uh visibility

05:47:37.479 --> 05:47:40.359
I we're gonna be using meter data that's uh either

05:47:40.369 --> 05:47:43.918
available in our system. Yes, ma'am.

05:47:47.180 --> 05:47:49.220
Ok. Oh yes, I need, we'll see if I can quickly.

05:47:56.729 --> 05:48:00.529
First of all, we'll be uh for competitive choice areas

05:48:00.540 --> 05:48:02.838
We're gonna be using the meter data, the premise level

05:48:02.850 --> 05:48:06.128
meter data to evaluate and I forgot what would we end

05:48:06.140 --> 05:48:12.168
up the la uh the top um how many intervals um Now

05:48:12.180 --> 05:48:15.579
that actually change got modified to some extent it

05:48:15.588 --> 05:48:18.569
did. Yeah, so, so here's the, here's the test here

05:48:18.579 --> 05:48:23.619
that we got right now. Yeah, so uh no more than 25%

05:48:23.628 --> 05:48:28.119
of the highest price days with an average load uh reduction

05:48:28.128 --> 05:48:31.248
greater than 5% of those days will be deemed price

05:48:31.260 --> 05:48:34.350
responsible. So we'll be running that test using the

05:48:34.359 --> 05:48:38.439
meter data, premise, level meter data uh that's available

05:48:38.449 --> 05:48:43.859
will just be, if we find that uh if, if you submit

05:48:43.869 --> 05:48:48.079
a aggregation with sites, uh we'll be running this

05:48:48.088 --> 05:48:51.769
test. Um And then we'll be returning if we find out

05:48:51.779 --> 05:48:54.760
there are easy I DS that are going to do not meet

05:48:54.769 --> 05:48:58.918
that criteria will be returning that to the uh to the

05:48:58.930 --> 05:49:02.899
entity that's, that's submitted that resource. And

05:49:02.909 --> 05:49:06.220
if there's time available, they can opt to modify their

05:49:06.229 --> 05:49:11.180
their uh their offer into the service in the well,

05:49:11.189 --> 05:49:13.540
the no areas, they're going to have to submit meter

05:49:13.549 --> 05:49:16.939
data on a timely manner for us to be able to do

05:49:16.949 --> 05:49:19.810
that same verification. Since that meter data is not

05:49:19.819 --> 05:49:24.088
available to us, we do the same thing with es for,

05:49:24.100 --> 05:49:27.689
for, for aggregations that are, that are sent to us

05:49:27.699 --> 05:49:30.739
that are offered in and no service territories. What's

05:49:30.748 --> 05:49:35.989
the responsibility? What's that? What is in that? Excuse

05:49:35.998 --> 05:49:38.329
me, I'm gonna have to interrupt for a moment. We are

05:49:38.338 --> 05:49:41.119
broadcasting on Texas admin and if you do not speak

05:49:41.128 --> 05:49:43.899
into a microphone, people cannot hear. So please get

05:49:43.909 --> 05:49:45.439
to a microphone if you have a question.

05:49:47.560 --> 05:49:50.918
OK. So while we're at it, I think for our broadcast

05:49:50.930 --> 05:49:54.279
situation, it's gonna work a lot better for c to complete

05:49:54.290 --> 05:49:56.810
their presentation. And then we'll have folks come

05:49:56.819 --> 05:49:59.619
up to the microphones at the table to ask their questions

05:49:59.628 --> 05:50:04.369
Ok, thanks. That sounds great. Thank you, Connie. Before

05:50:04.378 --> 05:50:07.600
we move on to the next slide, I I think it might

05:50:07.609 --> 05:50:11.989
be helpful to explain some of the policy for why we

05:50:11.998 --> 05:50:17.680
established the, the criteria for eligibility. Um All

05:50:17.689 --> 05:50:23.128
of these were intended to compensate new capacity that

05:50:23.140 --> 05:50:27.748
would be available for dispatch. So entities that already

05:50:27.760 --> 05:50:31.310
engage in, for example, demand response, whether that's

05:50:31.319 --> 05:50:34.159
because they're simply price versus and don't want

05:50:34.168 --> 05:50:37.779
to incur the costs of paying for energy during high

05:50:37.790 --> 05:50:41.180
price periods or they're engaged in some sort of load

05:50:41.189 --> 05:50:44.338
management or demand response program, we didn't want

05:50:44.350 --> 05:50:48.390
load to have to pay for performance that already occurs

05:50:48.949 --> 05:50:51.748
Likewise, that's why we have the limitations with respect

05:50:51.760 --> 05:50:54.079
to the qualified generation resources. All of this

05:50:54.088 --> 05:50:58.100
is intended to procure new behavior, new dispatch ability

05:51:03.918 --> 05:51:06.600
OK. My name is Austin Roselle. I'm with ERCOT. I got

05:51:06.609 --> 05:51:10.199
two slides here on the financials, financial related

05:51:10.208 --> 05:51:10.779
slides.

05:51:12.909 --> 05:51:14.229
So we got the um

05:51:16.109 --> 05:51:19.519
oh, I'll just go through here. So, so for starters

05:51:19.529 --> 05:51:23.609
um all participation for all participation types,

05:51:25.140 --> 05:51:28.760
E SRS generation resources, demand response, the hourly

05:51:28.769 --> 05:51:31.260
standby payments that we determine are going to be

05:51:31.269 --> 05:51:34.899
based on the offers and specific to the entity that

05:51:34.909 --> 05:51:36.869
made the offer. It's not going to be a clearing price

05:51:36.878 --> 05:51:43.739
type situation. Thank you. Um Protocol section 6511

05:51:43.909 --> 05:51:46.319
who talks about this, this procurement process requires

05:51:46.329 --> 05:51:50.430
us to uh follow substantially the same conditions as

05:51:50.439 --> 05:51:55.699
an RMR. Uh settlement situation. So we are doing that

05:51:55.708 --> 05:51:57.540
But then you'll see me point out a couple of times

05:51:57.549 --> 05:51:59.470
where we deviate from that, we're substantially like

05:51:59.479 --> 05:52:02.310
it, but we're deviating from that somewhat. And one

05:52:02.319 --> 05:52:05.208
of these situations is the incentive factor that we

05:52:05.220 --> 05:52:08.489
use in uh settlements is limited to 10% in the current

05:52:08.498 --> 05:52:11.628
protocols. There's a spot on these offer sheets. We're

05:52:11.640 --> 05:52:13.680
developing offer sheets, we submitted a draft and we're

05:52:13.689 --> 05:52:15.689
coming out with new ones on Monday for each of the

05:52:15.699 --> 05:52:18.609
types. There is actually a spot on there to designate

05:52:18.619 --> 05:52:22.189
the incentive factor for um E sr SS and generation

05:52:22.199 --> 05:52:26.498
resources. So we will allow that to go above 10%. What

05:52:26.510 --> 05:52:29.869
is the incentive factor? It's basically a um percentage

05:52:29.878 --> 05:52:35.628
adder on non fuel, non capital costs um That the uh

05:52:35.689 --> 05:52:38.378
entity recovers through the um through the settlement

05:52:38.390 --> 05:52:40.970
that actually can be subject to uh reductions as well

05:52:40.979 --> 05:52:42.659
based on performance. And I'll talk about that in a

05:52:42.668 --> 05:52:43.010
minute.

05:52:45.199 --> 05:52:48.220
Uh OK. So three types of settlements, right? Generation

05:52:48.229 --> 05:52:50.199
resource settlement, energy storage resource, settlement

05:52:50.208 --> 05:52:52.918
and demand response, generation resource and energy

05:52:52.949 --> 05:52:56.378
storage resource are essentially the same like I said

05:52:56.390 --> 05:52:58.720
before. The substantially the same as you see under

05:52:58.729 --> 05:53:02.760
an RMR which is all in the section 666 of the protocols

05:53:04.359 --> 05:53:06.600
One difference between the two is the way the settlement

05:53:06.609 --> 05:53:09.909
is set up in the protocols, hourly standby payments

05:53:10.029 --> 05:53:14.510
and are made. These are all the uh the payments also

05:53:14.519 --> 05:53:18.019
include compensation for fuel. We pay for the fuel

05:53:18.029 --> 05:53:20.930
burned for generation resources. We don't have protocols

05:53:20.939 --> 05:53:24.159
that cover that for energy storage resources. So we

05:53:24.168 --> 05:53:27.409
will, we it will be uh outlined in the governing document

05:53:27.418 --> 05:53:29.310
that's coming out on Monday as well, but we will actually

05:53:29.319 --> 05:53:32.850
be compensating for charging costs in place of uh fuel

05:53:32.859 --> 05:53:39.010
fuel recovery costs. Um High level the settlement is

05:53:39.029 --> 05:53:41.140
a, so this is going through the existing settlement

05:53:41.149 --> 05:53:44.458
processes, existing real time settlement invoices and

05:53:44.470 --> 05:53:48.769
statements. It's a hourly granularity type settlement

05:53:48.779 --> 05:53:53.168
that occurs daily uh allocated to load the same way

05:53:53.180 --> 05:53:56.668
hourly via the normal settlement statements. Um There

05:53:56.680 --> 05:54:00.029
will be some adjustments on the final intro settlements

05:54:00.040 --> 05:54:03.748
as we evaluate performance and whatnot. Um But uh it

05:54:03.760 --> 05:54:05.930
should flow, it will flow through the regular settlement

05:54:05.939 --> 05:54:09.790
processes and that includes the uh how you set up with

05:54:09.819 --> 05:54:12.168
ERCOT credit requirements, et cetera. That'll all flow

05:54:12.180 --> 05:54:14.418
through the current, the current processes.

05:54:17.659 --> 05:54:20.189
Um Oh yeah. One thing I didn't mention here, the second

05:54:20.199 --> 05:54:22.989
bullet in the second section in the third section here

05:54:23.720 --> 05:54:26.159
So we will reimburse charging costs based on what we

05:54:26.168 --> 05:54:28.619
see in our settlement system, the meter price and the

05:54:28.628 --> 05:54:32.689
consumption through the through the meter. The charging

05:54:32.699 --> 05:54:34.970
side of the battery actually can receive ancillary

05:54:34.979 --> 05:54:37.918
service and balance payments for charging. So we will

05:54:37.930 --> 05:54:40.540
net those payments out with the with the uh charging

05:54:40.549 --> 05:54:41.810
cost when we do the settlement.

05:54:46.149 --> 05:54:49.989
Uh next slide, please. Thank you. Ok. So another place

05:54:49.998 --> 05:54:54.739
we're deviating slightly from the current arm R protocols

05:54:55.390 --> 05:54:58.779
is in regards to the um reduction due to decrease a

05:54:58.829 --> 05:55:01.790
decreased availability and performance. Right now,

05:55:01.799 --> 05:55:05.600
the incentive factor is based on availability uh with

05:55:05.609 --> 05:55:08.449
a six month look back period, we're going to change

05:55:08.458 --> 05:55:11.909
that to just looking at an operating month and looking

05:55:11.918 --> 05:55:13.799
at the total performance during that operating month

05:55:13.810 --> 05:55:15.799
and using that to reduce the incentive factor instead

05:55:15.810 --> 05:55:18.760
of looking at a six month period for a three month

05:55:19.918 --> 05:55:20.588
products.

05:55:22.998 --> 05:55:25.329
Ok. Demand response settlement will be quite a bit

05:55:25.338 --> 05:55:28.439
different. It will not be through a QSC

05:55:30.729 --> 05:55:35.149
ERCOT will develop direct relationships with the entities

05:55:35.159 --> 05:55:38.878
that represent the demand response. Well, wire wire

05:55:38.890 --> 05:55:40.819
funds directly. I was told by our treasury will be

05:55:40.829 --> 05:55:43.079
wiring, not writing checks, not cutting checks. Fy

05:55:43.088 --> 05:55:48.699
I um so uh we'll establish direct relationships with

05:55:48.708 --> 05:55:50.369
these entities. So that means they, they will not be

05:55:50.378 --> 05:55:52.869
going through the normal processes with RCO in terms

05:55:52.878 --> 05:55:56.470
of credit collateral, um setting up agreements and

05:55:56.479 --> 05:55:58.989
et cetera. So because of that, we are not going to

05:55:58.998 --> 05:56:02.100
settle with the demand response until after we've evaluated

05:56:02.109 --> 05:56:05.540
the performance of the demand response. So it'll, it'll

05:56:05.549 --> 05:56:08.588
be a monthly settlement. It'll occur after performance

05:56:08.600 --> 05:56:11.269
has been determined and the final settlement has occurred

05:56:11.279 --> 05:56:14.529
for that month. So if you got an example here, the

05:56:14.540 --> 05:56:17.109
December operating month, the settlement will likely

05:56:17.119 --> 05:56:20.338
be late February early March of 2024.

05:56:22.279 --> 05:56:25.290
So that gives time for the demand response folks to

05:56:26.100 --> 05:56:29.060
get the meter data submitted through the evaluations

05:56:29.729 --> 05:56:31.729
determine what the payment should be. Calculate the

05:56:31.739 --> 05:56:34.890
payments. Uh I I believe it's the outline in the governing

05:56:34.899 --> 05:56:37.470
document. There'll be some information that goes back

05:56:37.479 --> 05:56:40.829
to, to those entities so they can, can uh you know

05:56:40.838 --> 05:56:46.369
verify, verify our math. And by then the final settlement

05:56:46.378 --> 05:56:49.269
should have occurred. 55 occurs 55 days after the operating

05:56:49.279 --> 05:56:52.359
day. So the plan is to allocate, it'll be an hourly

05:56:52.369 --> 05:56:54.628
allocation, but we'll just do a one invoice for the

05:56:54.640 --> 05:56:57.149
month. So the one invoice that encompasses all the

05:56:57.159 --> 05:56:59.878
settlements for that for that operating month. And

05:56:59.890 --> 05:57:03.149
that'll be based on the uh meter data we get on the

05:57:03.159 --> 05:57:05.659
final settlement and the plans for it to be one and

05:57:05.668 --> 05:57:08.989
done, we settle it on the final and that's it. So there

05:57:08.998 --> 05:57:12.060
should be no need to try to claw back payments we already

05:57:12.069 --> 05:57:13.760
made to the demand response providers because they

05:57:13.769 --> 05:57:14.689
didn't perform et cetera

05:57:16.829 --> 05:57:21.168
one and done. Um I think I kind of already covered

05:57:21.180 --> 05:57:23.350
my third bullet here, but it will be a miscellaneous

05:57:23.359 --> 05:57:25.659
invoice after the final settlement is done.

05:57:28.248 --> 05:57:30.199
And those are my, those are my two slides.

05:57:34.049 --> 05:57:37.069
Ok, Nathan, you wanna cover the hours of obligation

05:57:38.649 --> 05:57:44.140
Uh Sure thing. So the hours of obligation are going

05:57:44.149 --> 05:57:48.180
to differ depending on the technology type. If it's

05:57:48.189 --> 05:57:50.989
a generation resource, it's going to have to be available

05:57:50.998 --> 05:57:54.869
all hours of every day during the contract period.

05:57:55.279 --> 05:57:58.220
And there is no limit on the number or the duration

05:57:58.229 --> 05:58:02.708
of the deployments of a generation resource for demand

05:58:02.720 --> 05:58:07.628
response resources. They have an option of choosing

05:58:08.189 --> 05:58:13.519
um any of these four categories of hours. Um And URCO

05:58:13.619 --> 05:58:17.549
will award them for only one of them. Um Option one

05:58:17.560 --> 05:58:21.208
category one is all hours of every day. Category two

05:58:21.220 --> 05:58:24.628
is all hours during the period from our ending five

05:58:24.640 --> 05:58:28.100
through our ending 10. And option three, category three

05:58:28.109 --> 05:58:31.350
is all hours during the period from our ending 18 through

05:58:31.359 --> 05:58:35.479
our earning 23. And category four is all hours during

05:58:35.489 --> 05:58:39.180
both our earning five through our earning 10 and our

05:58:39.189 --> 05:58:44.319
earning 18 through our earning 23. So Dr also has a

05:58:44.329 --> 05:58:46.609
limit on the number of deployments and that's going

05:58:46.619 --> 05:58:49.269
to be three times during the contract period, limited

05:58:49.279 --> 05:58:53.189
to six hours of deployment at a time and only during

05:58:53.199 --> 05:58:56.260
those hours of obligation, category one through four

05:58:56.269 --> 05:59:00.519
whichever was awarded in the contract. So E SRS um

05:59:00.529 --> 05:59:03.869
again, we've as DeVita pointed out, we have clarified

05:59:04.239 --> 05:59:09.010
the requirements um and allowances for E Sr S um in

05:59:09.019 --> 05:59:12.128
the forthcoming governing document and the RFP, they

05:59:12.140 --> 05:59:15.439
are going to be allowed to select among the same hours

05:59:15.449 --> 05:59:19.378
of obligation as demand response except for they will

05:59:19.390 --> 05:59:22.159
not be allowed to offer to be available all hours of

05:59:22.168 --> 05:59:27.739
every day. So ESRs unlike Dr are not going to be limited

05:59:27.748 --> 05:59:31.040
on the number of deployments and the duration will

05:59:31.049 --> 05:59:35.569
be limited to the hours of obligation. So that's, that's

05:59:35.579 --> 05:59:37.019
a summary on our of obligation.

05:59:41.299 --> 05:59:44.878
Ok. And so tho those are kind of the key key takeaways

05:59:44.890 --> 05:59:48.479
from the questions that we received. Here's some other

05:59:48.489 --> 05:59:51.220
key responses that we wanted to just go ahead and highlight

05:59:51.229 --> 05:59:53.329
on the next two slides and, and DaVita, maybe I'll

05:59:53.338 --> 05:59:54.760
ask you to kind of walk through this

05:59:57.409 --> 05:59:59.850
and, and they don't, they're not going to be incorporated

05:59:59.859 --> 06:00:03.290
into the RFP. But obviously, people had policy questions

06:00:03.299 --> 06:00:05.549
as well. And so we wanted to highlight some of the

06:00:05.829 --> 06:00:09.359
some of the policy questions that we received. And

06:00:09.369 --> 06:00:13.430
as Chad previously mentioned, the questions that we

06:00:13.439 --> 06:00:17.029
received that were common. Um We attempted to incorporate

06:00:17.040 --> 06:00:20.208
in prior parts of the presentation. Um These were some

06:00:20.220 --> 06:00:24.019
one offs or, or key policy cuts that we wanted to um

06:00:24.540 --> 06:00:28.838
directly answer and explain. One was regarding um use

06:00:28.850 --> 06:00:32.338
of DC ties, whether or not um we would seek to procure

06:00:32.350 --> 06:00:36.260
capacity outside of our balancing authority. And the

06:00:36.269 --> 06:00:42.149
answer is no. Um And that's because um DC ties, um

06:00:42.369 --> 06:00:45.260
the provision of power of the DC ties cannot be guaranteed

06:00:45.269 --> 06:00:47.958
during a period of emergency. It's contingent upon

06:00:48.069 --> 06:00:51.299
NRC reliability requirements and also our agreements

06:00:51.310 --> 06:00:53.769
with the other balancing authorities with DC ties with

06:00:53.779 --> 06:00:56.619
us because it can't be guaranteed during periods of

06:00:56.628 --> 06:00:58.510
emergency. We, we don't want to pay for that.

06:01:00.430 --> 06:01:04.799
Uh Another question was about aggregation of capacity

06:01:04.810 --> 06:01:06.958
sources. And there were questions and concerns as to

06:01:06.970 --> 06:01:10.338
whether or not it would be limited to um outside of

06:01:10.498 --> 06:01:13.869
noi territories or specific weather zones or load zones

06:01:13.899 --> 06:01:17.029
And um we don't intend to have any limitations on uh

06:01:17.040 --> 06:01:18.569
ability to aggregate.

06:01:23.689 --> 06:01:28.409
Another question was about um whether or not um Noys

06:01:28.909 --> 06:01:33.939
would um um be required to provide authorization for

06:01:33.949 --> 06:01:37.350
any demand response um sites that were located in their

06:01:37.359 --> 06:01:40.989
service area. Um We concluded that although this is

06:01:40.998 --> 06:01:45.729
a wholesale capacity service um in recognition of provisions

06:01:45.739 --> 06:01:49.329
requiring um no e authorization for other demand response

06:01:49.338 --> 06:01:52.748
programs that we have like es or for those entities

06:01:52.760 --> 06:01:56.479
that actually load resources um requiring no authorization

06:01:56.489 --> 06:01:59.609
that we would require no authorization here. And so

06:01:59.619 --> 06:02:01.829
among the red lines that we're going to be providing

06:02:01.838 --> 06:02:06.430
on Monday is um a ne authorization form and it's modeled

06:02:06.439 --> 06:02:09.359
after the ne authorization form that we already have

06:02:09.369 --> 06:02:11.010
for um es.

06:02:18.560 --> 06:02:22.458
Um Another question was noting that we hadn't addressed

06:02:22.470 --> 06:02:26.909
baselines in the original RP and draft governing document

06:02:27.189 --> 06:02:31.659
And in response, we um will be using the baseline methodology

06:02:31.668 --> 06:02:35.040
that we've used for other demand response. And, and

06:02:35.049 --> 06:02:38.180
that's available at the link to URL. It will be the

06:02:38.189 --> 06:02:41.149
exact same methods that we use um to establish other

06:02:41.159 --> 06:02:41.899
baselines.

06:02:45.319 --> 06:02:47.560
We asked, we received questions about whether or not

06:02:47.569 --> 06:02:50.909
T SPS and D SPS are eligible to participate in the

06:02:50.918 --> 06:02:55.458
program. And at this time, the answer is no and Finally

06:02:55.470 --> 06:03:00.128
we were asked about um how any dispatch of, of capacity

06:03:00.140 --> 06:03:03.329
sources procured for this um would be mitigated in

06:03:03.338 --> 06:03:07.760
wholesale prices. I I welcome the experts to, to supplement

06:03:07.769 --> 06:03:11.359
this answer. Um But the, the key points that we wanted

06:03:11.369 --> 06:03:15.489
to make were that um and the energy offers from these

06:03:15.498 --> 06:03:17.649
capacity sources will have to be offered in at the

06:03:17.659 --> 06:03:22.088
system wide cap including the mitigated offer cap curve

06:03:22.100 --> 06:03:25.949
Um If any of these um capacity sources are ultimately

06:03:25.958 --> 06:03:29.529
deployed by RCO T, um they'll be limited to times of

06:03:29.540 --> 06:03:33.470
real or forecasted emergency conditions. And um when

06:03:33.479 --> 06:03:36.569
they would be dispatched is um um more specifically

06:03:36.579 --> 06:03:41.088
addressed in the, the governing document. And finally

06:03:41.100 --> 06:03:45.029
um the dispatch of any generation resources would be

06:03:45.040 --> 06:03:49.010
um reflected as an adjustment to the RDP A. Um the

06:03:49.019 --> 06:03:51.979
RDP A wouldn't be adjusted for demand response. And

06:03:51.989 --> 06:03:54.248
that's because we actually don't have a mechanism to

06:03:54.260 --> 06:03:54.829
do that.

06:04:01.220 --> 06:04:04.458
OK? I think that kind of completes the, the overall

06:04:04.470 --> 06:04:08.359
presentation. Um We obviously posted our responses

06:04:08.369 --> 06:04:10.609
on Wednesday. I'm sure a lot of y'all have looked at

06:04:10.619 --> 06:04:14.479
them. So we're happy to open it up for questions now

06:04:14.489 --> 06:04:16.739
Just I want to make sure you come here and you ask

06:04:16.748 --> 06:04:17.510
your questions,

06:04:25.079 --> 06:04:27.600
Greg Turner representing Tesla Energy. Uh I'd like

06:04:27.609 --> 06:04:30.529
to start by thanking ERCOT uh for the time and effort

06:04:30.540 --> 06:04:32.619
you put into this. I realize that you're navigating

06:04:32.659 --> 06:04:35.498
a very difficult time in the energy transition and

06:04:35.510 --> 06:04:38.109
have put forth a lot of effort to come up with a

06:04:38.119 --> 06:04:41.019
way to reduce risk and, and unlike, it's unlikely that

06:04:41.029 --> 06:04:45.540
everyone will be happy with, with the program and as

06:04:45.549 --> 06:04:47.930
one of the entities that is less than happy with the

06:04:47.939 --> 06:04:53.310
program, um I wanted to ask a question about the testing

06:04:53.319 --> 06:04:57.168
for demand response. Uh As best I could tell from reading

06:04:57.180 --> 06:05:01.918
the RP, the random testing from the ES program was

06:05:01.930 --> 06:05:06.799
lifted and replicated in the RFP. And this I don't

06:05:06.810 --> 06:05:09.319
think is a problem unique to Tesla customers. Rather

06:05:09.350 --> 06:05:12.049
those customers who are residential and own a battery

06:05:12.060 --> 06:05:16.299
electric storage system often do so because they prefer

06:05:16.310 --> 06:05:19.659
to not use the grid. And in this offering, we're going

06:05:19.668 --> 06:05:23.088
to try and entice them to help the grid. And when we

06:05:23.100 --> 06:05:27.310
ask for that help, the first question or answer we

06:05:27.319 --> 06:05:31.790
try to provide is how often will I be called upon to

06:05:32.149 --> 06:05:36.439
provide a response? And with the random testing from

06:05:36.449 --> 06:05:41.229
ERRS, we have to be prepared to provide a response

06:05:41.239 --> 06:05:43.260
at any time. So you've essentially commandeered that

06:05:43.269 --> 06:05:46.269
device for 90 days. And I appreciate why the random

06:05:46.279 --> 06:05:48.449
testing is there and that it's there to verify that

06:05:48.458 --> 06:05:53.838
we can exercise the capability that we offered. But

06:05:53.850 --> 06:05:57.310
knowing that no powerwall or distributed energy storage

06:05:57.319 --> 06:05:59.489
customer bought that device with the intent of helping

06:05:59.498 --> 06:06:01.739
the grid. In fact, their help to the grid is being

06:06:01.748 --> 06:06:04.680
off grid and using that device to power their homes

06:06:04.689 --> 06:06:08.418
And get better use out of their solar. We're changing

06:06:08.430 --> 06:06:12.970
the ask. And since this program is unique in that es

06:06:12.979 --> 06:06:16.579
is designed to respond to any given emergency. Maybe

06:06:16.588 --> 06:06:19.338
it's a resource trip, maybe it's unexpected weather

06:06:19.350 --> 06:06:23.159
maybe it's a change in renewables. This program seems

06:06:23.168 --> 06:06:27.628
to be targeted at responding to winter events that

06:06:27.640 --> 06:06:32.208
are easy to forecast. So, is that another way? Winter

06:06:32.220 --> 06:06:34.359
storm Uri? We knew a week in advance. We had a tough

06:06:34.369 --> 06:06:38.079
situation coming up. Same with winter storm Elliott

06:06:38.109 --> 06:06:42.140
same with the winter storms of 2011, 2012. You name

06:06:42.149 --> 06:06:44.418
it. We're trying to ensure against events that are

06:06:44.430 --> 06:06:45.458
very predictable.

06:06:47.079 --> 06:06:51.149
The ask is that, er, reconsider the random test which

06:06:51.159 --> 06:06:53.958
could be any day in 90 days, effectively rendering

06:06:53.970 --> 06:06:56.220
that device unavailable for the customers use for the

06:06:56.229 --> 06:06:59.369
entirety of the contract period including Bluebird

06:06:59.378 --> 06:07:01.810
days where we all remember those Texas, Decembers and

06:07:01.819 --> 06:07:04.850
January where we are golfing in short pants. They can't

06:07:04.859 --> 06:07:07.939
use that to reduce their electric bill. They can't

06:07:07.949 --> 06:07:11.799
use that to utilize their solar. They're sitting waiting

06:07:11.810 --> 06:07:16.540
and charging potentially off grid every day to be ready

06:07:16.549 --> 06:07:20.970
to respond to a random test. If we could make that

06:07:20.979 --> 06:07:24.208
random test window akin to the notice, we would get

06:07:24.449 --> 06:07:27.399
to precondition the devices in advance of a winter

06:07:27.409 --> 06:07:31.680
storm like Uri or Elliott, we would have a much better

06:07:31.689 --> 06:07:35.149
uptake because we could define when we have to take

06:07:35.159 --> 06:07:38.269
the ability for the customer to use that device and

06:07:38.279 --> 06:07:39.310
prioritize

06:07:40.918 --> 06:07:43.790
a random test or winter event if we can constrain that

06:07:43.799 --> 06:07:45.918
the opportunity cost as perceived by the customer is

06:07:45.930 --> 06:07:48.519
much lower. And I appreciate you listening to this

06:07:48.529 --> 06:07:51.589
ask to reconsider that random test to be a 48 or 72

06:07:51.598 --> 06:07:56.938
hour window rather than unannounced. Um And I asked

06:07:56.948 --> 06:07:59.088
because I didn't like the answer I got in writing and

06:07:59.098 --> 06:08:01.127
didn't have the opportunity to explain why. So thank

06:08:01.137 --> 06:08:03.017
you for your time and consideration in that matter

06:08:10.499 --> 06:08:10.900
for that.

06:08:20.910 --> 06:08:20.928
Yeah,

06:08:23.649 --> 06:08:28.618
so, so Greg uh just a cla clarifying question is your

06:08:28.627 --> 06:08:32.508
hypothetical one where the the the batteries would

06:08:32.517 --> 06:08:36.547
be um exporting to the grid or would they be offsetting

06:08:36.957 --> 06:08:41.139
um residential demand? They can do either and we would

06:08:41.150 --> 06:08:45.139
express their capability based upon if it was a baseline

06:08:45.150 --> 06:08:47.279
it would be reducing premise load. If it were to be

06:08:47.290 --> 06:08:50.040
allowed that we could use device level metering, it

06:08:50.049 --> 06:08:52.189
would be based on injection to serve premise load.

06:08:54.139 --> 06:08:56.639
Yeah. So, so and, and just to be clear here, you know

06:08:56.650 --> 06:08:59.900
the original concept of allowing negative load to participate

06:08:59.910 --> 06:09:02.699
is not going to be carried forward to the next iteration

06:09:02.999 --> 06:09:06.508
of the document at this point. However, um offsetting

06:09:06.719 --> 06:09:09.779
the premise load is, is still permitted. I think there's

06:09:09.790 --> 06:09:11.969
different methodologies whether it's device level or

06:09:11.980 --> 06:09:16.439
premise level, um you know, validation of that performance

06:09:16.449 --> 06:09:21.088
that are available as I understand. Um But uh that

06:09:21.098 --> 06:09:24.267
may color um you know what's what's available right

06:09:24.278 --> 06:09:26.387
now, as you point out there is an allowance for us

06:09:26.399 --> 06:09:30.939
to test at any time. Um, whether we should give notice

06:09:30.949 --> 06:09:33.480
of the test for 48 hours, 72 hours, I think is a

06:09:33.490 --> 06:09:35.389
policy question. It's on my background.

06:09:39.069 --> 06:09:43.799
Yeah, I'm, yes. First of all, a couple of different

06:09:43.809 --> 06:09:47.669
things for the sake of, of trying to implement this

06:09:47.678 --> 06:09:50.878
in the short period of time that we had to, I would

06:09:50.889 --> 06:09:55.639
still like to go back to um we wouldn't be using device

06:09:55.650 --> 06:10:00.199
level validation. I think it should be premise level

06:10:00.208 --> 06:10:02.609
validation because that's data, that's much easier

06:10:02.619 --> 06:10:08.639
for us to, to analyze. Ok. Um As far as testing, first

06:10:08.650 --> 06:10:10.279
of all, just to make it clear, you would, you would

06:10:10.290 --> 06:10:13.119
only be subject to a test within the category that

06:10:13.128 --> 06:10:15.598
you're participating in as demand response. If you're

06:10:15.609 --> 06:10:19.019
participating only as category two or three, then you

06:10:19.029 --> 06:10:22.219
would only be tested. And during that six hour window

06:10:22.540 --> 06:10:24.589
in the morning or six hour window in the afternoon

06:10:24.598 --> 06:10:27.378
if you're category one, I would think you should be

06:10:27.389 --> 06:10:31.169
subject to a test at any time as far as giving you

06:10:31.178 --> 06:10:35.359
advanced notice. I, I kind of agree with your premise

06:10:35.369 --> 06:10:40.830
that winter issues are somewhat known to be coming

06:10:41.219 --> 06:10:45.859
Uh I have no, no problem uh with, with saying giving

06:10:45.869 --> 06:10:48.848
you a warning of, you know, we're gonna test somewhere

06:10:48.859 --> 06:10:51.928
in the next 48 hours or something like that. I, I don't

06:10:51.939 --> 06:10:55.049
have a problem with that at all. As long as ERCOT doesn't

06:10:55.059 --> 06:10:57.348
see other issue, other people with ERCOT don't have

06:10:57.359 --> 06:10:59.258
an issue with that. So,

06:11:03.240 --> 06:11:07.098
did I cover all of your questions there? And is somebody

06:11:07.109 --> 06:11:12.139
capturing them? I'm just kidding. Ok. Ok. All right

06:11:13.869 --> 06:11:17.178
Thank you. I'm Kathy Webb King here on behalf of team

06:11:17.549 --> 06:11:21.059
Um I think our questions primarily go around to the

06:11:21.070 --> 06:11:25.019
idea of cost and ultimately induced customer cost and

06:11:25.029 --> 06:11:28.320
I have not seen in this, if there's any budget, does

06:11:28.330 --> 06:11:32.889
ERCOT anticipate any limit on what you would pay for

06:11:32.900 --> 06:11:37.219
this um now called capacity service?

06:11:42.098 --> 06:11:45.428
No answer. Go ahead. All right. We, we don't have a

06:11:45.439 --> 06:11:47.958
budget set. We don't have a limit set. We want to see

06:11:47.969 --> 06:11:49.999
what the offers come in and look like and evaluate

06:11:50.008 --> 06:11:52.678
what is reasonable for the amount of megawatts and

06:11:52.689 --> 06:11:55.799
and to see if the uh the value is there. So we

06:11:55.809 --> 06:11:57.589
didn't want to prejudice by saying we've got a cap

06:11:57.598 --> 06:11:59.189
or a limit or this is what, you know, we're going to

06:11:59.199 --> 06:12:01.499
pay at this point. So I think we need to see what

06:12:01.508 --> 06:12:03.919
comes in and see what's reasonable and try to decide

06:12:03.928 --> 06:12:07.990
that collectively. Uh and when you say decide collectively

06:12:07.999 --> 06:12:11.499
do you mean ERCOT decide internal to ERCOT, unilaterally

06:12:11.508 --> 06:12:14.939
making a recommendation? Um and process wise, how does

06:12:14.949 --> 06:12:18.480
that work? So, I mean, ultimately, ERCOT staff gets

06:12:18.490 --> 06:12:21.598
to make the decision under this existing process and

06:12:21.949 --> 06:12:24.980
and uh of course, we'll, we'll obviously be coordinating

06:12:24.990 --> 06:12:27.689
with the commission on, you know, our decision points

06:12:27.699 --> 06:12:30.359
But um you know, consistent with Pablo said, we did

06:12:30.369 --> 06:12:32.549
not want to prejudice, you know, what offers would

06:12:32.559 --> 06:12:36.139
look like. And we really wanted to, to see how this

06:12:36.150 --> 06:12:38.889
framework would operate under this tight timeline,

06:12:38.900 --> 06:12:41.650
which we all agree. It's a very tight timeline. Um

06:12:41.660 --> 06:12:43.869
You know, I think I said this at the board, we understand

06:12:43.878 --> 06:12:47.119
the reality of the generation resources that were on

06:12:47.128 --> 06:12:49.848
the list, but we think this is a good way to see

06:12:49.859 --> 06:12:52.109
what's available on the demand side and see how they

06:12:52.119 --> 06:12:52.758
offer in.

06:12:55.660 --> 06:12:59.279
And from that as we move forward, we will take the

06:12:59.290 --> 06:13:02.098
lessons learned, incorporate those in the protocols

06:13:02.109 --> 06:13:05.279
continue to work with the commission on, you know,

06:13:05.290 --> 06:13:12.958
refining this process. Thank you, Chan. Um So as you

06:13:12.969 --> 06:13:15.859
can imagine to try to price that into a customer service

06:13:15.869 --> 06:13:21.139
contract is impossible. Um So there is that aspect

06:13:21.150 --> 06:13:24.019
that I think we would need to be working with co and

06:13:24.029 --> 06:13:26.089
the commission in terms of looking at this as a new

06:13:26.119 --> 06:13:30.169
ERCOT fee that is yet undefined and um certainly beyond

06:13:30.178 --> 06:13:33.230
the ability to plan or hedge for in the, in the contracts

06:13:33.678 --> 06:13:37.208
Um And in addition, I think I heard some disconnect

06:13:37.219 --> 06:13:41.008
between when the settlement charges might actually

06:13:41.019 --> 06:13:44.189
come through versus the settlement payments, which

06:13:44.199 --> 06:13:48.820
add additional complexity to that. Um Is that right

06:13:48.999 --> 06:13:52.299
I'm not sure what the disconnect was. I'll try maybe

06:13:52.309 --> 06:13:54.230
saying it again and then tell me if I, if I get

06:13:54.240 --> 06:13:56.799
it or you want to explain, let me if I could just

06:13:56.999 --> 06:14:00.258
you set up for the demand response services, they wouldn't

06:14:00.269 --> 06:14:03.469
be paid until after the final settlement timeline because

06:14:03.480 --> 06:14:05.628
you need time to evaluate their actual performance

06:14:05.639 --> 06:14:09.208
Yes, ma'am. But when would be charged for those services

06:14:09.219 --> 06:14:12.348
at a similar time line around the same time just right

06:14:12.359 --> 06:14:17.169
after. So it should be or actually sorry right before

06:14:17.178 --> 06:14:18.749
right, we got to pull the money in and then give it

06:14:18.758 --> 06:14:22.820
out. But it would be um 55 days after the end of

06:14:22.830 --> 06:14:25.969
the month. So it would be kind of like a regular settlement

06:14:25.980 --> 06:14:28.128
today, bring the money in, put it out. It's all one

06:14:28.139 --> 06:14:31.128
kind of process based on the load ratio share back

06:14:31.139 --> 06:14:35.809
in the back on operating day. Yes, so yes, the hourly

06:14:35.820 --> 06:14:39.580
load ratio shares for the month as of the final settlement

06:14:40.258 --> 06:14:42.208
And we ultimately think that's a good protection to

06:14:42.219 --> 06:14:45.080
load because we're not going to be charging load until

06:14:45.089 --> 06:14:47.428
we see what the performance is on the demand response

06:14:47.439 --> 06:14:51.139
side. And because we're allowing so much flexibility

06:14:51.150 --> 06:14:53.820
on how we're handling the settlement process with those

06:14:53.830 --> 06:14:56.199
direct entities because they're not, we're not asking

06:14:56.208 --> 06:14:58.559
for a qualified scheduling entity. We're not trying

06:14:58.570 --> 06:15:00.990
to get any type of collateral from them. It really

06:15:00.999 --> 06:15:05.290
is a performances mechanism to see how they perform

06:15:05.419 --> 06:15:08.139
before we assess any charges to L

06:15:10.910 --> 06:15:14.040
I understand that there, as you imagine on the retail

06:15:14.049 --> 06:15:16.049
side, there's a lot of complexities to that, that load

06:15:16.059 --> 06:15:19.269
may not be still the load of the entity that's being

06:15:19.279 --> 06:15:22.508
charged anymore. So there's, there's complications

06:15:22.519 --> 06:15:24.919
there, but I appreciate the, the response. Thank you

06:15:28.859 --> 06:15:31.359
Maybe ahead of the next question. I'll, I'll answer

06:15:31.369 --> 06:15:36.169
the one that was asked before, before ERCOT resumed

06:15:36.178 --> 06:15:38.869
our presentation. Um The question was asked about the

06:15:38.878 --> 06:15:42.678
timeliness of meter data from Noys. Was that one of

06:15:42.689 --> 06:15:44.160
the one of the questions?

06:15:45.919 --> 06:15:46.410
Ok.

06:15:51.689 --> 06:15:53.639
That's right. We were talking about the verification

06:15:53.650 --> 06:15:57.150
process for purposes of determining that the customer

06:15:57.160 --> 06:15:59.639
is not uh previously priced responsive or however,

06:15:59.650 --> 06:16:02.439
that's worded. Uh Emily Jelly with LC A. Thank you

06:16:03.619 --> 06:16:06.628
So I think it's spelled down on the governing document

06:16:06.639 --> 06:16:10.650
but we definitely have to have the meter data provided

06:16:10.660 --> 06:16:13.499
to. If so it's on a noise service territory. We're

06:16:13.508 --> 06:16:15.820
going to have to have the meter data provided to RCO

06:16:15.830 --> 06:16:19.928
T at least by the time the offer is submitted to OT

06:16:19.939 --> 06:16:24.208
I mean, that's at the very latest. Um If you want to

06:16:24.219 --> 06:16:28.740
if you can submit your meter data and even a list of

06:16:28.749 --> 06:16:32.949
easy I DS even ahead of time. Uh before you actually

06:16:32.958 --> 06:16:35.848
make your formal offer that can give us some time to

06:16:35.859 --> 06:16:40.490
run the, the validation and submit that back to you

06:16:40.499 --> 06:16:43.928
And if there are any easy I DS in that aggregation

06:16:43.939 --> 06:16:46.949
that, that don't pass that test, then you have the

06:16:46.958 --> 06:16:50.279
opportunity to remove them and modify your, your offer

06:16:50.290 --> 06:16:52.980
before the offer submission deadline. That's what I

06:16:52.990 --> 06:16:56.980
would recommend if, if, if you can, but it has to be

06:16:56.990 --> 06:16:59.708
definitely be, be submitted to by the time of the offer

06:16:59.719 --> 06:17:03.219
submission. And would ERCOT consider including as part

06:17:03.230 --> 06:17:06.290
of the verification process and check with that customer's

06:17:06.299 --> 06:17:09.820
LC. Um because you know, pri price responsive is a

06:17:09.830 --> 06:17:13.480
vacuous term and I think we're understanding that that

06:17:13.490 --> 06:17:18.139
means something uh beyond um formal participation in

06:17:18.150 --> 06:17:19.779
an ERCOT administered program.

06:17:21.519 --> 06:17:25.299
I didn't catch the nuance of what you were asking us

06:17:25.309 --> 06:17:29.089
to include a verification check with a load serving

06:17:29.098 --> 06:17:35.249
entity. Who the load serving entity is that the customer

06:17:35.258 --> 06:17:40.639
is in fact not price responsive for the terms of what

06:17:40.650 --> 06:17:44.139
you're laying out contractually with that LSE.

06:17:45.758 --> 06:17:48.139
I don't know how we can. Well, I mean, I know that

06:17:48.150 --> 06:17:51.199
we have this annual price responsiveness survey that

06:17:51.208 --> 06:17:54.439
we run, but this I think is, is reporting, proposing

06:17:54.449 --> 06:17:57.919
to use a more quantitative assessment for what is price

06:17:57.928 --> 06:18:02.029
responsive. That is the same all across the board um

06:18:02.040 --> 06:18:05.900
for all LSES. And so there, there's going to be a quantifiable

06:18:05.910 --> 06:18:09.258
metric as, as we mentioned earlier for, for that test

06:18:09.269 --> 06:18:11.549
Um So I don't, I don't know that it's really a matter

06:18:11.559 --> 06:18:14.900
of at a station um As much as it is a matter

06:18:14.910 --> 06:18:19.240
of um the um you know what the meter data demonstrate

06:18:19.249 --> 06:18:23.799
as far as as that as that quality. That makes sense

06:18:23.990 --> 06:18:28.369
It does and I'm happy to follow up with you more offline

06:18:28.378 --> 06:18:31.469
Nathan about how y'all considered that check. Um I

06:18:31.480 --> 06:18:34.669
I wanna go back to if, if I can ask more questions

06:18:34.719 --> 06:18:38.119
Thank you. Um I wanna go back to understand the authority

06:18:38.128 --> 06:18:40.609
that ERCOT is proposing this under and, and Chad I

06:18:40.619 --> 06:18:43.820
think you gave us a protocols reference. Um Can you

06:18:43.830 --> 06:18:46.458
provide that reference for everyone in the room and

06:18:46.469 --> 06:18:49.699
also identify what if any protocols or other revision

06:18:49.708 --> 06:18:52.859
requests would need to be modified to account for this

06:18:52.869 --> 06:18:56.458
program? So I think the protocol reference is probably

06:18:56.469 --> 06:19:01.740
right there on the screen. 65114. Is that correct Davina

06:19:02.299 --> 06:19:04.969
That is right. OK. So you know the uh most of y'all

06:19:04.980 --> 06:19:07.910
know the history here, right? In the summer of 2011

06:19:08.128 --> 06:19:11.769
uh working with the commission coming out of the extreme

06:19:12.029 --> 06:19:14.839
uh February event heading into the hottest summer on

06:19:14.848 --> 06:19:19.169
record, we were asked to look at uh capacity related

06:19:19.178 --> 06:19:23.290
resources in August of 2011. And we ended up procuring

06:19:23.299 --> 06:19:25.958
four generation resources to get us through the rest

06:19:25.969 --> 06:19:28.660
of the summer. Uh There was no protocol language at

06:19:28.669 --> 06:19:31.779
that time and the commission and the stakeholders wanted

06:19:31.790 --> 06:19:34.109
protocol language. So this is the language that was

06:19:34.119 --> 06:19:38.910
put in after the summer of 2011 that we have never

06:19:38.919 --> 06:19:43.348
used until now. And so we are using this protocol language

06:19:43.359 --> 06:19:47.589
to come out with our RP and notice that we did in

06:19:47.598 --> 06:19:51.428
uh October 2nd, I believe. And this is the, the protocol

06:19:51.439 --> 06:19:54.639
section that I think once we go through this exercise

06:19:54.790 --> 06:19:58.029
that and we take all the lessons learned and feedback

06:19:58.040 --> 06:20:00.848
from everybody that we would go in and, and continue

06:20:00.859 --> 06:20:04.240
to work on this language. And so can you describe for

06:20:04.249 --> 06:20:09.330
us how this process that's envisioned under 6511 paragraph

06:20:09.339 --> 06:20:12.719
four is the same or is different from the enhanced

06:20:12.730 --> 06:20:16.749
RMR um option that was identified by ERCOT as a potential

06:20:16.758 --> 06:20:17.910
bridge solution.

06:20:23.098 --> 06:20:27.269
I don't know, do you know exactly what the solution

06:20:27.540 --> 06:20:29.758
the bridge solution, what we were talking about? I

06:20:29.980 --> 06:20:32.410
don't think we ever kind of really formally move forward

06:20:32.419 --> 06:20:35.628
with laying out all those parameters. It was an option

06:20:35.639 --> 06:20:39.400
on the table and you know, we did presented to the

06:20:39.669 --> 06:20:41.660
board and then ultimately to the commission that was

06:20:41.669 --> 06:20:45.598
not, not endorsed by the board or the commission, right

06:20:46.410 --> 06:20:48.969
I don't know what an endorsement means, but it didn't

06:20:48.980 --> 06:20:51.958
move forward. Right. In fact, the ERCOT board and the

06:20:51.969 --> 06:20:55.689
commission endorsed the ORC step changes as the preferred

06:20:55.699 --> 06:20:59.169
bridge solution. Is that your understanding chad is

06:20:59.178 --> 06:21:00.230
this a deposition

06:21:02.059 --> 06:21:04.749
that I think we all know that we moved forward with

06:21:04.758 --> 06:21:07.549
the O DC pricing floors and we're in the process of

06:21:07.559 --> 06:21:12.359
implementing that. Um can you share with us what communications

06:21:12.499 --> 06:21:15.839
ERCOT has had with the eligible generation resource

06:21:15.848 --> 06:21:18.889
owners about the likelihood of their participation

06:21:18.900 --> 06:21:23.559
in the RFP that I cannot because I wasn't responsible

06:21:23.570 --> 06:21:25.439
for that task. So, so I don't know if anybody else

06:21:25.449 --> 06:21:29.059
on, on this team has had active communications with

06:21:29.070 --> 06:21:32.249
them. Um You know, there's been a handful of emails

06:21:32.258 --> 06:21:36.070
that have come in and, but as far as like hand holding

06:21:36.080 --> 06:21:38.900
and talking to them about the RPI, I can't answer that

06:21:38.910 --> 06:21:39.580
So I don't know.

06:21:41.139 --> 06:21:43.458
So for those who may have had those communications

06:21:43.469 --> 06:21:46.178
that may be in the room here, we just want to avoid

06:21:46.189 --> 06:21:49.480
being specific about particular generators. But I think

06:21:49.490 --> 06:21:51.958
we could speak in general terms if there is knowledge

06:21:51.969 --> 06:21:53.098
among the folks in this room.

06:21:55.330 --> 06:21:58.098
And I think earlier, we did hear from some representatives

06:21:58.109 --> 06:22:01.359
of some of those resource entities. Was that new information

06:22:01.389 --> 06:22:05.469
to ERCOT today when you heard the unlikelihood of their

06:22:05.480 --> 06:22:08.049
return or is that something that you all had anticipated

06:22:08.059 --> 06:22:10.740
when you put this together? Does that change your approach

06:22:10.749 --> 06:22:13.019
at all? Is really what I'm trying to understand given

06:22:13.029 --> 06:22:16.230
the feedback that you might have heard today? No, I

06:22:16.299 --> 06:22:18.699
mean, what, what our goal is to be transparent through

06:22:18.708 --> 06:22:21.900
this entire process, which is why we listed every available

06:22:22.439 --> 06:22:26.559
resource that was sitting on the sideline. Their availability

06:22:26.570 --> 06:22:29.580
and capability to come back is within their decision

06:22:29.859 --> 06:22:33.458
Sure. So is ERCOT still going to look to procure up

06:22:33.469 --> 06:22:36.809
to 3000 megawatts if it's all demand response at the

06:22:36.820 --> 06:22:40.049
end of the day? I think we will ultimately see what

06:22:40.059 --> 06:22:43.279
the offers look like and consider costs. And we've

06:22:43.290 --> 06:22:46.428
been very clear about that. Um

06:22:48.049 --> 06:22:50.410
I don't want to dominate the floor, but I do, speaking

06:22:50.419 --> 06:22:52.889
of looking at Greg, speaking of Q and A answers, we

06:22:52.900 --> 06:22:57.830
didn't like very much. Um looking at the RDP, RDP A

06:22:57.839 --> 06:23:00.389
impacts, I guess we're not persuaded by the response

06:23:00.400 --> 06:23:02.740
that that's not something that ERCOT can evaluate and

06:23:02.749 --> 06:23:05.348
account for. Given the information that is required

06:23:05.359 --> 06:23:09.199
in the RP. Uh would ERCOT be open to considering uh

06:23:09.208 --> 06:23:13.410
a different approach on that issue. So I think Dave

06:23:13.669 --> 06:23:20.119
Maggio is on Dave. Are you able to hear us? Yes. Can

06:23:20.128 --> 06:23:23.758
you all hear me? All right, you wanna take that one

06:23:23.769 --> 06:23:27.799
Dave? Yeah, sure. I, I would say that really the, the

06:23:27.809 --> 06:23:32.320
main problem we have and I think it's linked to largely

06:23:32.330 --> 06:23:35.619
the flexibility we are trying to have in terms of um

06:23:35.669 --> 06:23:38.339
allowing for multiple types of demand response and

06:23:38.348 --> 06:23:41.609
and Chad and others spoke about this a little bit before

06:23:42.269 --> 06:23:45.059
but, you know, really, unlike everything else that

06:23:45.070 --> 06:23:47.980
we have in the protocol that's included in the RDP

06:23:47.990 --> 06:23:52.290
A process, we really don't have that information available

06:23:52.299 --> 06:23:56.258
to any systems digitally to try to account for those

06:23:56.269 --> 06:24:00.119
types of deployments in the RDP A. So I think we are

06:24:00.128 --> 06:24:02.949
really stuck in a bind where that, that information

06:24:02.958 --> 06:24:05.330
is simply not available in real time for the purpose

06:24:05.339 --> 06:24:06.240
of those calculations.

06:24:14.559 --> 06:24:17.080
Do you have more questions Emily or I do don't let

06:24:17.098 --> 06:24:19.389
someone else have some night.

06:24:23.269 --> 06:24:26.059
Well, our next question is coming up. I will note that

06:24:26.070 --> 06:24:29.678
the market notice and the RP provide the citations

06:24:29.689 --> 06:24:32.339
to the protocol section um giving us the authority

06:24:32.348 --> 06:24:34.049
to seek to contract for capacity.

06:24:36.290 --> 06:24:39.939
Hi, so Christina Rollins uh for NRG I had a question

06:24:39.949 --> 06:24:41.230
about um

06:24:43.790 --> 06:24:47.419
enforcement of performance. So some of these customers

06:24:47.428 --> 06:24:50.098
on the demand response side, you said could participate

06:24:50.109 --> 06:24:53.320
you know, without um going through a queasy. And so

06:24:53.330 --> 06:24:55.939
this might be more a question for Nathan and Chad and

06:24:55.949 --> 06:24:59.639
DaVita. And so have y'all given any thought to if there

06:24:59.650 --> 06:25:02.769
is nonperformance? Right? And the customer doesn't

06:25:02.779 --> 06:25:06.740
perform is the penalty you don't pay them or is there

06:25:06.749 --> 06:25:09.928
something else attached with that? Right? Because you

06:25:09.939 --> 06:25:12.779
know, typically if you have a resource entity or another

06:25:12.790 --> 06:25:16.040
entity that doesn't perform, there could be an enforcement

06:25:16.049 --> 06:25:18.428
like at the commission or ERCOT has jurisdictional

06:25:18.439 --> 06:25:21.580
authority over them. So here, what are these customers

06:25:21.589 --> 06:25:25.458
considered with respect to Ur's view of market participants

06:25:25.469 --> 06:25:28.309
And what should they expect if for whatever reason

06:25:28.320 --> 06:25:29.219
they can't perform

06:25:31.939 --> 06:25:34.889
right now? What we have envisioned in the protocols

06:25:34.900 --> 06:25:37.779
and the governing document is just a claw in the case

06:25:37.790 --> 06:25:41.199
of demand response of customers just a clawback for

06:25:41.208 --> 06:25:45.708
for nonperformance as to whether or not the commission

06:25:45.719 --> 06:25:48.549
who ultimately would be the entity taking any enforcement

06:25:48.559 --> 06:25:50.820
action, whether or not they have authority that that's

06:25:50.830 --> 06:25:54.609
really outside of our purview to comment upon just

06:25:54.619 --> 06:25:57.660
to clarify. I think the word clawback might mean something

06:25:57.669 --> 06:26:00.089
specific. We don't pay them. That's a great point.

06:26:00.119 --> 06:26:01.949
It's a reduced payment. So, yeah.

06:26:03.490 --> 06:26:06.299
Ok. Thank you one more plug for the summer only thing

06:26:08.699 --> 06:26:08.859
the same.

06:26:11.258 --> 06:26:16.249
So I've got a follow up on that. So kind of looking

06:26:16.258 --> 06:26:21.990
around the corner. So any load that was price responsive

06:26:23.128 --> 06:26:25.878
right? So that would, that would, so if, if it, if

06:26:25.889 --> 06:26:27.708
it had been price responsive in the past, it would

06:26:27.719 --> 06:26:32.458
be ruled out. However, if it was in a summer program

06:26:32.469 --> 06:26:38.400
but not in a winter program, we have some, um we're

06:26:38.410 --> 06:26:43.628
gonna have to look at that and see if the summer responsiveness

06:26:43.639 --> 06:26:48.320
actually affects the winter forecast. And if it did

06:26:48.330 --> 06:26:51.669
affect the winter forecast, then we will have already

06:26:51.678 --> 06:26:54.119
thought about it when we think about those levels.

06:26:54.339 --> 06:26:57.240
And so that's the, that's the problem. I think though

06:26:57.410 --> 06:27:02.160
if it didn't affect the winter forecast and what is

06:27:02.169 --> 06:27:05.139
being offered is something we wouldn't have otherwise

06:27:05.249 --> 06:27:08.008
something brand new for the winner, then it probably

06:27:08.019 --> 06:27:10.519
could be considered. But we'll have to, we'll have

06:27:10.529 --> 06:27:14.740
to clarify that on Monday when we publish the final

06:27:14.749 --> 06:27:19.070
rule, but we will look at that. So for a load that

06:27:19.080 --> 06:27:21.598
participated in the summer, but there is no winter

06:27:21.609 --> 06:27:26.150
participation. Um, is that truly a new load or has

06:27:26.160 --> 06:27:27.859
it already been accounted for? And so we'll, we'll

06:27:27.869 --> 06:27:30.249
take a look at that and get that clarified. I appreciate

06:27:30.258 --> 06:27:32.369
that clarification and it sounds like on the price

06:27:32.378 --> 06:27:35.160
responsiveness, y'all are looking at it mainly from

06:27:35.169 --> 06:27:37.719
a behavioral standpoint, right? Regardless of contract

06:27:37.730 --> 06:27:39.910
It's what did the customer actually do during these

06:27:39.919 --> 06:27:42.678
periods that you're going to select to determine whether

06:27:42.689 --> 06:27:45.109
or not it was actually price responsive? That's right

06:27:45.219 --> 06:27:46.249
Ok, thank you.

06:27:54.428 --> 06:27:54.458
Ok.

06:27:58.529 --> 06:28:01.980
I thought we were friends, we were friends at one time

06:28:01.990 --> 06:28:06.029
I think there's a long story behind that. Uh My name

06:28:06.040 --> 06:28:09.508
is Jim Galvin. I'm with United Cooper Services in uh

06:28:09.519 --> 06:28:13.758
Burleton Texas. The question really pertains to the

06:28:13.769 --> 06:28:17.269
protocol under RR and it's a genuine question because

06:28:17.279 --> 06:28:19.320
I haven't reviewed it in some time. But are we able

06:28:19.330 --> 06:28:22.469
to adjust some of those parameters or are those parameters

06:28:22.480 --> 06:28:24.240
set forth in the RR

06:28:26.580 --> 06:28:28.189
protocols? As is right now?

06:28:30.928 --> 06:28:34.889
Uh You look like you're looking at me, I am. Uh so

06:28:34.900 --> 06:28:37.859
when you say parameters for in terms of settlements

06:28:37.869 --> 06:28:40.119
is involved, the adjustment factor, as you mentioned

06:28:40.128 --> 06:28:43.490
that you were changing from 10%. Yes, availability

06:28:43.499 --> 06:28:47.428
factor. I'm sorry. So it's yes, they're adjustable

06:28:47.910 --> 06:28:50.980
It's not a simple adjustment. It's a manual process

06:28:50.990 --> 06:28:54.008
So it may look a little funny, adjustable under protocol

06:28:54.019 --> 06:28:56.928
language. Oh, is it adjustable to put it? Well, I think

06:28:56.939 --> 06:29:00.419
I might need to lean on. Uh We're supposed to uh what's

06:29:00.428 --> 06:29:03.499
what's the word uh substantially be substantially similar

06:29:03.508 --> 06:29:08.080
to the RMR settlement under this contract for capacity

06:29:08.089 --> 06:29:12.049
So, in my opinion, yes, we can vary some of these parameters

06:29:12.059 --> 06:29:14.249
somewhat as long as we're substantially the same. But

06:29:14.258 --> 06:29:17.189
my question really is and maybe this is for follow

06:29:17.199 --> 06:29:21.008
up at some time, can do the protocols support the changing

06:29:21.019 --> 06:29:25.219
of those parameters. Um Likewise, do the protocols

06:29:25.230 --> 06:29:30.589
support settlement with a non QSE. And what I'm getting

06:29:30.598 --> 06:29:34.619
at here is potential risk of cash flow through the

06:29:34.628 --> 06:29:39.339
dispute process on potential opportunities for this

06:29:39.348 --> 06:29:42.969
exercise that are deemed not according to protocol

06:29:43.540 --> 06:29:45.799
And then my last question associated with that would

06:29:45.809 --> 06:29:49.098
therefore be what is going to be done with respect

06:29:49.109 --> 06:29:52.419
to credit? And how are these costs going to be incorporated

06:29:52.428 --> 06:29:55.428
in collateral requirements? It's another cost to load

06:29:55.439 --> 06:29:58.559
serving entities, all entities really, aside from the

06:29:58.570 --> 06:30:02.848
ones that uh Kathy Webb can identify. Do you want to

06:30:02.910 --> 06:30:04.719
talk about, let me, let me first address kind of the

06:30:04.730 --> 06:30:07.279
threshold. I think underlying legal question and then

06:30:07.290 --> 06:30:08.790
maybe we can talk about the credit piece. And I, I

06:30:09.160 --> 06:30:12.730
think um as Austin intimated that there's, there's

06:30:12.740 --> 06:30:15.910
language in the 6511 paragraph for that talks about

06:30:15.919 --> 06:30:18.910
how the settlement processes here have to be substantially

06:30:18.919 --> 06:30:22.559
similar to what we have under RMR four generation resources

06:30:23.139 --> 06:30:25.279
four generation four generation resource that correct

06:30:25.290 --> 06:30:29.199
that is an important point as well. Um And so um where

06:30:29.208 --> 06:30:32.019
we deem that appropriate, you know, we have followed

06:30:32.029 --> 06:30:34.359
those parameters as closely as we can in the case of

06:30:34.369 --> 06:30:36.980
demand response. Obviously, there, you've got to depart

06:30:36.990 --> 06:30:39.519
from that because there is no specificity of what that

06:30:39.529 --> 06:30:42.258
looks like under RMR because you can't RMR a load,

06:30:42.559 --> 06:30:45.290
you can have Mr A, but that's not what's being imported

06:30:45.299 --> 06:30:48.320
into this, this framework here. So uh we certainly

06:30:48.330 --> 06:30:50.839
don't view this as being contrary to protocols. We

06:30:50.848 --> 06:30:54.098
view this as being within the ambit of what is contemplated

06:30:54.348 --> 06:30:57.699
in in section 6511. This of course is the first time

06:30:57.708 --> 06:31:00.519
we've ever actually done this procurement, right? So

06:31:00.529 --> 06:31:02.678
there's a little bit of rust to be shaken off here

06:31:02.689 --> 06:31:04.708
in terms of exactly how this is supposed to be work

06:31:04.719 --> 06:31:07.469
how this is supposed to work. Um We are creating some

06:31:07.480 --> 06:31:10.139
things from whole cloth here, you know, to begin with

06:31:10.639 --> 06:31:13.820
Um but we, we're trying to make this a fair and transparent

06:31:13.830 --> 06:31:18.128
process when it makes sense um that um that considers

06:31:18.139 --> 06:31:21.008
demand response generation resources and energy source

06:31:21.019 --> 06:31:23.249
resources as viable candidates to participate in this

06:31:23.258 --> 06:31:27.178
program. And I can appreciate that. But again, it goes

06:31:27.189 --> 06:31:30.040
back to the unintended cost that none of us have been

06:31:30.049 --> 06:31:33.320
able to hedge for up until this time. And I do appreciate

06:31:33.330 --> 06:31:37.939
the paradigm here that we really need to look at reliability

06:31:37.949 --> 06:31:41.089
for this winter. But I think the transparency with

06:31:41.098 --> 06:31:44.660
respect to total costs including the impact of capacity

06:31:44.669 --> 06:31:49.080
payments on all load serving entities as well as any

06:31:49.089 --> 06:31:53.230
energy and recompensation for fuel. And the like really

06:31:53.240 --> 06:31:56.070
has to be looked at in the full scope and not so

06:31:56.080 --> 06:31:57.570
much as an exercise.

06:31:59.480 --> 06:32:04.299
That's my concern. Fair enough. Yeah, this, yeah, the

06:32:04.309 --> 06:32:07.029
cost is obviously a a relevant consideration and is

06:32:07.040 --> 06:32:10.410
going to be part of the evaluation. Um We want to ensure

06:32:10.419 --> 06:32:12.378
as chad indicated earlier that we're getting value

06:32:12.389 --> 06:32:15.490
for money when we evaluate these offers. So let me

06:32:15.508 --> 06:32:18.740
pause and let Austin talk about the credit. Yes. So

06:32:18.790 --> 06:32:21.449
in regards to the credit piece, there's like there's

06:32:21.458 --> 06:32:24.439
two main, two main areas, right? There's the ESR and

06:32:24.449 --> 06:32:26.309
the generation resource which is going through the

06:32:26.320 --> 06:32:29.139
current settlement processes. And there's the demand

06:32:29.150 --> 06:32:34.119
response part for the first part, that's, you know

06:32:34.128 --> 06:32:37.320
the the the parameters that can, can vary. Those are

06:32:37.330 --> 06:32:39.589
those are built in right now in the RMR process just

06:32:39.598 --> 06:32:41.859
based on the the budget or whatever we could get from

06:32:42.008 --> 06:32:46.589
a, from an RMR from a normal RMR resource. So there

06:32:46.598 --> 06:32:49.910
is, there's already some variability risk built into

06:32:49.919 --> 06:32:54.330
those equations. Um They are flowing through the normal

06:32:54.339 --> 06:32:56.589
settlement processes because they're being captured

06:32:56.598 --> 06:32:59.449
on regular uh statements and invoices. So I really

06:32:59.458 --> 06:33:04.799
think for the uh the um capital R type resources, I

06:33:04.809 --> 06:33:07.708
don't think there is any real incremental credit issues

06:33:08.169 --> 06:33:12.480
based on on this um contract for capacity, not above

06:33:12.490 --> 06:33:14.339
any a normal RMR and things that have already been

06:33:14.348 --> 06:33:18.570
baked and built into the protocols for the demand response

06:33:18.580 --> 06:33:20.619
that you know, that was a concern and that's why I

06:33:20.628 --> 06:33:23.089
stepped in and and talked to, correct to be on the

06:33:23.098 --> 06:33:25.549
use of the word claw back. We didn't want to make a

06:33:25.559 --> 06:33:28.919
standby payment to the demand response resources who

06:33:28.928 --> 06:33:31.809
are not Qses. We don't, we don't have these agreements

06:33:31.820 --> 06:33:34.939
with and then try to chase them down if, if, uh, they

06:33:34.949 --> 06:33:37.598
didn't perform and, and, and claw the money back. So

06:33:37.609 --> 06:33:40.570
that's why we're, we're holding back, um, payments

06:33:40.580 --> 06:33:43.019
until after we can evaluate performance and pay them

06:33:43.029 --> 06:33:44.939
for what they actually did. And that's why they, there's

06:33:45.330 --> 06:33:47.820
you know, a two month over a two month waiting period

06:33:47.830 --> 06:33:51.059
to, to get your first payment if you're a demand response

06:33:51.508 --> 06:33:55.639
Um in terms of the load exposure based on that, it

06:33:55.650 --> 06:33:58.910
is somewhat accounted for in the credit equations via

06:33:58.949 --> 06:34:02.269
mis miscellaneous invoice. So that will though those

06:34:02.279 --> 06:34:04.529
um miscellaneous invoices that go out load, they will

06:34:04.540 --> 06:34:07.299
get pulled into our, our credit calculation processes

06:34:07.570 --> 06:34:09.469
Um They won't be extrapolated forward. They'll be,

06:34:09.480 --> 06:34:11.339
be handled like a miscellaneous invoice if you're familiar

06:34:11.348 --> 06:34:14.080
with, with how those work. But, but there is some consideration

06:34:14.089 --> 06:34:18.189
there for um for the load side of the uh demand response

06:34:18.199 --> 06:34:19.559
side of the equation.

06:34:28.320 --> 06:34:31.458
We think my disease, we promise

06:34:34.820 --> 06:34:39.378
ST uh Taylor Carro on behalf of TPP A. Uh I wanna

06:34:39.389 --> 06:34:43.958
thank y'all for posting these presentations uh doing

06:34:43.969 --> 06:34:47.378
the Q and A that's all been really helpful um in reviewing

06:34:47.389 --> 06:34:50.219
the RCO website where a lot of this is hosted. I did

06:34:50.230 --> 06:34:54.299
note that it seems like mostly uh the rfps that are

06:34:54.309 --> 06:34:59.490
posted there, current rfps Open rfps. And due to the

06:34:59.499 --> 06:35:02.559
amount of work that y'all put into this, due the novelty

06:35:02.570 --> 06:35:06.779
of this, I do worry that once this RP closes, we might

06:35:06.790 --> 06:35:09.809
lose some of that information. And so I just want to

06:35:09.820 --> 06:35:13.348
ask if y'all wouldn't mind either. Probably a lot of

06:35:13.359 --> 06:35:15.779
the documents, the governing documents, the Q and A

06:35:16.219 --> 06:35:19.070
uh perhaps in this workshops docket or a different

06:35:19.080 --> 06:35:21.848
docket that staff prefers if you wouldn't mind, just

06:35:21.859 --> 06:35:24.650
making sure that uh some of the work that y'all have

06:35:24.660 --> 06:35:27.540
done. The immense work that y'all have done is preserved

06:35:27.549 --> 06:35:29.839
especially like if Chad said, we're gonna go and do

06:35:29.848 --> 06:35:32.040
uh some protocol revisions on this later on

06:35:40.458 --> 06:35:43.428
Taylor, I'll just, I'll just add that or just mention

06:35:43.439 --> 06:35:46.749
that we have filed the, the Q and A uh just today

06:35:46.758 --> 06:35:50.439
um in the winter weather proceeding. So you can go

06:35:50.449 --> 06:35:52.769
ahead and find that there. Um I don't see any reason

06:35:52.779 --> 06:35:55.619
why we wouldn't want to file the final documents that

06:35:55.628 --> 06:35:58.019
are posted on Monday with the commission unless Chad

06:35:58.029 --> 06:35:59.098
has an objection to that,

06:36:00.669 --> 06:36:03.258
we can do whatever. I mean. So, and I, I think it's

06:36:03.269 --> 06:36:05.529
a good point. We'll figure out a different place to

06:36:05.540 --> 06:36:08.730
house this information as we move through the uh the

06:36:08.740 --> 06:36:11.519
remaining part of the RFP process. Thank you

06:36:13.279 --> 06:36:15.389
in the interest of being respectful of everybody's

06:36:15.400 --> 06:36:18.279
time and, and to permit the commission to resume its

06:36:18.290 --> 06:36:22.070
its workshop. What I was wondering if we have um many

06:36:22.080 --> 06:36:24.269
more questions. A few more questions cause we'll of

06:36:24.279 --> 06:36:26.029
course, wanna be respectful of everyone's time.

06:36:37.109 --> 06:36:40.609
I'm gonna be just, hi, Julia Harvey with the electric

06:36:40.619 --> 06:36:43.990
co ops. Thank you all for your work. Um Just a couple

06:36:43.999 --> 06:36:48.309
of clarifications on that question. 99 and, and 100

06:36:48.719 --> 06:36:52.230
I'm just presuming the intent wasn't to prohibit um

06:36:52.320 --> 06:36:55.208
you know, electric co ops or mo us from participating

06:36:55.219 --> 06:36:57.939
in the program as D SPS or T SPS. Can you all

06:36:57.949 --> 06:36:59.508
just confirm that or

06:37:02.208 --> 06:37:04.839
under the protocols? I do think we might, you know

06:37:04.848 --> 06:37:09.080
fall into those categories. So, I mean, I think what

06:37:09.089 --> 06:37:13.089
we're um contemplating is that, you know, entities

06:37:13.098 --> 06:37:17.199
that are coming up with um uh you know, new programs

06:37:17.208 --> 06:37:20.160
um to provide new capacity, could, could participate

06:37:20.169 --> 06:37:25.249
conceivably a no else in its role as an LSE. Um They

06:37:25.258 --> 06:37:28.139
may be able to bring something up in its role as A

06:37:28.150 --> 06:37:31.928
T DS P. I think structurally there is an issue there

06:37:31.939 --> 06:37:34.939
you know, with utilities offering these programs, you

06:37:34.949 --> 06:37:38.169
know, PURA has established authority for TD SPS to

06:37:38.178 --> 06:37:40.939
develop load management programs. The commission has

06:37:40.949 --> 06:37:43.040
allowed those as was discussed earlier today under

06:37:43.049 --> 06:37:49.119
the EECR filings as well. Um Those um those I think

06:37:49.128 --> 06:37:54.339
are narrow allowances um that, that uh are permitted

06:37:54.348 --> 06:37:58.499
for TD SPS, but to allow TD SPS as such, to develop

06:37:58.508 --> 06:38:01.299
market competing programs and what is a competitively

06:38:01.309 --> 06:38:06.119
procured market for capacity here. Um To us seems antithetical

06:38:06.128 --> 06:38:08.839
to the design under PURA, completely understand, I

06:38:08.848 --> 06:38:12.249
was just asking about non op entities that provide

06:38:12.258 --> 06:38:16.628
distribution service or transmission service. Right

06:38:16.639 --> 06:38:20.309
Still TD SPS, I guess is a concern but in the capacity

06:38:20.320 --> 06:38:22.230
Right? No, a TD SPS. Is that what you're asking about

06:38:22.240 --> 06:38:26.969
Correct? Yes. Right. I mean, so as TD SPS, um I mean

06:38:26.980 --> 06:38:30.589
that, that in that capacity where the P CS rules set

06:38:30.598 --> 06:38:34.160
out, um, you know, certain prohibitions against cross

06:38:34.258 --> 06:38:36.598
subsidization and separation between the different

06:38:36.609 --> 06:38:42.208
business units. I sort of my, my view, I would imagine

06:38:42.219 --> 06:38:45.619
that there is still that distinction between the utility

06:38:45.628 --> 06:38:50.540
business unit and the LSE function. Ok. Didn't mean

06:38:50.549 --> 06:38:52.699
to overcomplicate, it just was, was hoping we could

06:38:52.708 --> 06:38:55.189
be considered eligible to participate in the program

06:38:55.199 --> 06:38:57.809
and we are being asked to bring generators back in

06:38:57.839 --> 06:39:01.719
this program. So I just wanted to clarify that. But

06:39:02.730 --> 06:39:05.570
yeah, I mean, I guess you're saying because I know

06:39:05.580 --> 06:39:09.290
he is a T DS P is a prohibited category. Oh, no

06:39:09.320 --> 06:39:11.549
I don't think, I don't see a reason why that would

06:39:11.559 --> 06:39:15.769
be the case. I think it's because they also wear other

06:39:15.779 --> 06:39:20.199
hats that are, you know, competitive hats in some cases

06:39:20.669 --> 06:39:22.519
And certainly the wholesale market, I don't see a reason

06:39:22.529 --> 06:39:24.769
why they would be precluded from that, but it wouldn't

06:39:24.779 --> 06:39:27.549
be in their capacity to got it. Thank you so much.

06:39:27.559 --> 06:39:31.790
And then um regarding the participation in, in any

06:39:31.799 --> 06:39:36.098
other programs, any demand response programs. Um where

06:39:36.109 --> 06:39:40.019
there's this prohibition, if you're uh if you participate

06:39:40.029 --> 06:39:42.369
in existing program, I was wondering if that included

06:39:42.378 --> 06:39:46.980
like a net metering type program where say your, your

06:39:46.990 --> 06:39:51.320
utility is paying you for solar production. Um There's

06:39:51.330 --> 06:39:54.208
this possibility for maybe double payment under the

06:39:54.219 --> 06:39:57.650
RFP. Um Just wondering if that was comp contemplated

06:39:57.660 --> 06:39:58.169
at all.

06:40:02.389 --> 06:40:05.428
Yeah, I'm not sure, I'm not sure that net metering

06:40:05.439 --> 06:40:09.240
unless it impacts right, the actual um consumption

06:40:09.249 --> 06:40:11.389
that we're gonna be evaluating price response in this

06:40:11.400 --> 06:40:16.279
on um if that would, would preclude, I mean, part of

06:40:16.290 --> 06:40:19.178
the um you know, part of what we're gonna clarify in

06:40:19.189 --> 06:40:21.139
the documents we issue on Monday is that, you know

06:40:21.150 --> 06:40:24.119
even third party um programs, I think that's in the

06:40:24.128 --> 06:40:27.669
Q and A here, third-party programs um are also gonna

06:40:27.678 --> 06:40:31.249
be, you know, prohibited from, from participating if

06:40:31.258 --> 06:40:34.389
if it already existed as of the RFP date and we don't

06:40:34.400 --> 06:40:38.150
want that to uh participate because we already had

06:40:38.160 --> 06:40:41.848
it in a sense. Um And so that clarification is gonna

06:40:41.859 --> 06:40:46.699
be provided there. But um yeah, I yeah, I'm not sure

06:40:46.740 --> 06:40:50.070
if that, yeah, we can follow up on it. The something

06:40:50.080 --> 06:40:52.969
to look at, I'm sure you all have is the, the SPP

06:40:52.980 --> 06:40:58.589
compliance tariff for ferc order 2222 by four and shorthand

06:40:59.089 --> 06:41:01.779
that was filed recently and it, it goes into some of

06:41:01.790 --> 06:41:04.580
these issues. So there, there could be things to, to

06:41:04.589 --> 06:41:10.928
mimic from that compliance filing. Just a helpful suggestion

06:41:11.598 --> 06:41:13.809
if you can send anything to us by tomorrow. That'd

06:41:13.820 --> 06:41:16.958
be great. Ok. I think that covers it. Thank you.

06:41:24.029 --> 06:41:24.199
Ok.

06:41:28.869 --> 06:41:32.070
Um Sorry for the Sierra Club. We expressed a concern

06:41:32.080 --> 06:41:36.820
um, and just want to make sure that um, a in some

06:41:36.830 --> 06:41:41.339
ways will be reviewing and if any mothballed plants

06:41:41.540 --> 06:41:44.098
did want to participate, that you'll be reviewing that

06:41:44.109 --> 06:41:48.059
they have um operating permits from the regulator,

06:41:48.070 --> 06:41:50.258
which in this case would be TCQ. Was it, would that

06:41:50.269 --> 06:41:52.660
be the question? Is, would that be part of your process

06:41:55.939 --> 06:41:57.769
I guess, I don't know, specifically, it's a, if it's

06:41:57.779 --> 06:42:00.869
part of our process, I would assume that any generation

06:42:00.878 --> 06:42:04.678
resource offering and meets all regulatory requirements

06:42:05.160 --> 06:42:07.678
So, you know, we haven't specifically talked about

06:42:07.689 --> 06:42:09.799
are we going to go and then separately reach out to

06:42:09.919 --> 06:42:13.400
TCQ or EPA and confirm that? But that, that's just

06:42:13.410 --> 06:42:16.639
an obligation that every generation resource has. Correct

06:42:16.859 --> 06:42:19.589
Yeah, and we can't waive those obligations maybe more

06:42:19.598 --> 06:42:22.258
importantly is, you know, we have no power to mitigate

06:42:22.269 --> 06:42:24.859
what TCQ or EPA may do. So, compliance with those will

06:42:24.869 --> 06:42:25.758
be, will be required.

06:42:33.359 --> 06:42:39.290
Hi. Um I just wanted to Katie Coleman T IC. I wanted

06:42:39.299 --> 06:42:42.969
to just make sure I understand how y'all are interpreting

06:42:42.980 --> 06:42:48.089
some things. Um So when we did this back in 2011, there's

06:42:48.098 --> 06:42:50.428
a provision in the protocols that says basically if

06:42:50.439 --> 06:42:53.529
anybody gets a capital contribution through a program

06:42:53.540 --> 06:42:55.859
like this that they have to refund it before they re

06:42:55.869 --> 06:42:59.790
enter the market. When I read the protocols, I view

06:42:59.799 --> 06:43:02.279
that as applying to this, but I want to make sure that

06:43:02.290 --> 06:43:07.080
you all agree with that. Yeah, we do. OK, thank you

06:43:07.540 --> 06:43:10.839
Um And then there's also a provision saying that the

06:43:10.848 --> 06:43:14.330
resource can't participate in the energy or bilateral

06:43:14.439 --> 06:43:16.799
ancillary service markets while they're under contract

06:43:16.809 --> 06:43:19.779
And is that going to apply as well? Yes, yes. Then

06:43:19.790 --> 06:43:22.089
that's, you know, when we run it through the regular

06:43:22.169 --> 06:43:25.660
RMR settlements or any uh energy settlements and those

06:43:25.669 --> 06:43:27.799
kinds of things get unwound and those do get clawed

06:43:27.809 --> 06:43:31.160
back. And uh yeah, and then um

06:43:32.669 --> 06:43:35.958
I, I recognize the language on substantially follow

06:43:35.969 --> 06:43:41.089
the um RMR requirements and that you all are gonna

06:43:41.098 --> 06:43:44.309
maybe entertain deviation from that incentive factor

06:43:44.480 --> 06:43:48.650
But I'm curious if you have a view on what would be

06:43:48.660 --> 06:43:52.529
outside of substantial compliance with that 10% incentive

06:43:52.540 --> 06:43:57.889
factor, for example, 100%. I mean, where are you, what

06:43:57.900 --> 06:44:00.949
are the limits of what you guys will entertain on that

06:44:01.519 --> 06:44:03.859
I think that's another area that we want to see how

06:44:03.869 --> 06:44:07.410
they offer in and evaluate the overall cost to that

06:44:07.678 --> 06:44:11.299
So at this point, we're not at liberty to kind of say

06:44:11.309 --> 06:44:13.878
that we want to see how people consider the entire

06:44:13.900 --> 06:44:16.098
RFP framework and, and make their offers

06:44:18.029 --> 06:44:20.689
and will that be something that will be made public

06:44:20.699 --> 06:44:23.589
when the decisions are made, we'll be able to see what

06:44:23.598 --> 06:44:27.628
the incentive factor is. Yes. Well, you know, the offers

06:44:27.639 --> 06:44:30.240
will be public. I think that was on the, the one of

06:44:30.249 --> 06:44:33.749
the slides and uh ultimately the agreements will be

06:44:33.758 --> 06:44:38.730
public and there was some questions around customer

06:44:38.740 --> 06:44:41.598
information specifically that we addressed in the,

06:44:41.609 --> 06:44:44.628
in the responses on how we would handle that. So, very

06:44:44.639 --> 06:44:47.529
similar to how we handle the, the reliability services

06:44:47.540 --> 06:44:50.639
for RMR and uh Black Start Agreements, things like

06:44:50.650 --> 06:44:53.040
that, that we're going to be as transparent as possible

06:44:53.049 --> 06:44:55.309
with. Uh so that everybody understands the cost because

06:44:55.320 --> 06:44:59.669
load has to pay for this. Ok, thanks. And then um the

06:44:59.678 --> 06:45:03.109
last question is the way that this is written right

06:45:03.119 --> 06:45:08.109
now in the protocols. It's for the um current or upcoming

06:45:08.119 --> 06:45:10.859
season and I just wanna make sure that that's still

06:45:10.869 --> 06:45:13.859
everybody's understanding of the limits that this could

06:45:13.869 --> 06:45:18.619
be used for and not like winter next year in 2026 or

06:45:18.628 --> 06:45:21.660
anything like that. That's correct. That's, that's

06:45:21.669 --> 06:45:25.330
why this only goes to February. Ok, thank you.

06:45:35.169 --> 06:45:37.320
All right. Are there any other questions before we

06:45:37.330 --> 06:45:38.749
close the ERCOT workshop?

06:45:41.740 --> 06:45:44.490
Thank you very much for your interest. The questions

06:45:44.499 --> 06:45:47.080
that you've been asking and we look forward to continuing

06:45:47.089 --> 06:45:48.428
to work with you to see if we can get some more

06:45:48.439 --> 06:45:49.089
capacity.

06:45:56.080 --> 06:45:56.109
Ok.

06:45:59.089 --> 06:46:02.699
This concludes section four of staff's agenda before

06:46:02.708 --> 06:46:05.848
we begin. Section five, our commissioner discussion

06:46:06.070 --> 06:46:09.189
we're going to take a five minute break. And so the

06:46:09.199 --> 06:46:14.160
time is now 401 and we will be back at, let's say

06:46:14.169 --> 06:46:14.428
four

06:46:16.320 --> 06:46:19.619
time is now 4 11 and we'll resume our work session

06:46:20.080 --> 06:46:24.189
We'll begin with section five of staff's agenda, commissioner

06:46:24.199 --> 06:46:28.830
discussion on ERCOT S RFP. Let's start with questions

06:46:28.839 --> 06:46:33.008
that our market analysis staff may have of ERCOT and

06:46:33.019 --> 06:46:35.820
then the commissioners can ask our questions. So, uh

06:46:36.320 --> 06:46:39.128
would you like to kick things? We do have questions

06:46:39.139 --> 06:46:41.428
but we would like to take it up with URCO on our

06:46:41.439 --> 06:46:44.650
weekly Thursday calls. So that's what we are gonna

06:46:44.660 --> 06:46:48.208
do. Ok. Very good. Well, then, um, commissioners, any

06:46:48.219 --> 06:46:48.779
thoughts?

06:46:53.309 --> 06:46:53.999
Um

06:46:55.519 --> 06:47:01.178
So, um, the couple, one thing I think we need to address

06:47:01.859 --> 06:47:04.769
um, what has been posed as a part of the technical

06:47:04.779 --> 06:47:05.480
workshop?

06:47:08.419 --> 06:47:15.639
Is this and, and, and it's a question, is this a similar

06:47:15.660 --> 06:47:19.628
substantially similar proposal that was presented to

06:47:19.639 --> 06:47:25.098
the board and to the commission and as part of a bridging

06:47:25.109 --> 06:47:28.249
solution in February of this year.

06:47:29.980 --> 06:47:32.139
And, and the reason I asked, and the reason I asked

06:47:32.150 --> 06:47:35.449
that is because mechanically, it sounds somewhat similar

06:47:36.109 --> 06:47:42.820
and as 11 mind on the commission, that's not to say

06:47:42.830 --> 06:47:46.029
that ERCOT can't do what they're proposing right now

06:47:46.040 --> 06:47:49.830
There is a, what they assert is a reliability condition

06:47:49.878 --> 06:47:52.619
that could exist under certain circumstances, which

06:47:52.628 --> 06:47:56.458
is a winter storm Elliott equivalent condition in the

06:47:56.469 --> 06:48:01.029
winter. We know we have known demand growth going into

06:48:01.040 --> 06:48:04.769
the winter. And so the reason I ask that is because

06:48:04.779 --> 06:48:08.570
the, the question about what is the magnitude of cost

06:48:08.878 --> 06:48:15.070
comes up if this is in fact, was presented as a bridging

06:48:15.080 --> 06:48:18.258
solution, however, not adopted by the commission. But

06:48:18.269 --> 06:48:26.008
if it was House Bill 500 Section 39 PURA section 39

06:48:26.019 --> 06:48:35.348
1 594 subsection one A one which is the net cost of

06:48:35.359 --> 06:48:38.419
the ERCOT market of, of the credits does not exceed

06:48:38.428 --> 06:48:42.059
1 billion annually less the cost of any interim bridge

06:48:42.070 --> 06:48:45.348
solutions that are lawfully implemented, except that

06:48:45.359 --> 06:48:49.830
the commissions may adjust the limit would apply. And

06:48:49.839 --> 06:48:52.639
so my point is is that there is guidance in statute

06:48:53.040 --> 06:48:58.290
this, this ambiguity about how costs can be set uh

06:48:58.299 --> 06:49:02.958
constrained there, there is statutory precedent for

06:49:02.969 --> 06:49:07.650
that and it speaks to it. So my question for ERCOT

06:49:07.660 --> 06:49:11.098
is, what are we talking? What is, was this part of

06:49:11.109 --> 06:49:14.019
that bridging solution? Is that literally what we're

06:49:14.029 --> 06:49:17.570
talking about? Because I, because I pulled the documents

06:49:17.580 --> 06:49:20.598
from the board meeting from our considerations at the

06:49:20.609 --> 06:49:23.580
time. Granted the commission did not go that way. We

06:49:23.589 --> 06:49:27.369
went with the or DC. Well, neither did the board. That's

06:49:27.378 --> 06:49:30.580
correct. The board did not adopt it. Chad, what do

06:49:30.589 --> 06:49:35.839
you think Chad Seeley with ERCOT? No, it's a simple

06:49:35.848 --> 06:49:40.699
answer. So this is a tool that has been in the protocols

06:49:40.708 --> 06:49:44.758
for 10 plus years and it's a pinpoint tool which is

06:49:44.769 --> 06:49:47.650
why we have the questions that we had looking at the

06:49:47.660 --> 06:49:52.419
current season. And the next season, when we talked

06:49:52.428 --> 06:49:56.719
about the RMR for capacity concept as a bridging solution

06:49:56.730 --> 06:50:00.689
it really was a longer duration type solution knowing

06:50:00.699 --> 06:50:02.660
that we were working on the market initiatives and

06:50:02.669 --> 06:50:05.378
it was going to take time for the market to respond

06:50:05.389 --> 06:50:09.708
Now, we never got into the full build out of that framework

06:50:09.749 --> 06:50:12.309
because the commission wasn't interested and the board

06:50:12.320 --> 06:50:15.160
wasn't interested and we put more of our focus into

06:50:15.169 --> 06:50:18.769
the orc changes. But this is a reliability tool that's

06:50:18.779 --> 06:50:21.749
in the protocols that has existed for a decade. And

06:50:21.758 --> 06:50:24.969
this is what we're using. Recognizing the risk profile

06:50:24.980 --> 06:50:27.258
that we see for the upcoming winter season.

06:50:30.540 --> 06:50:34.008
Welcome. Any thoughts ca ca can I follow up on that

06:50:34.019 --> 06:50:39.919
since you're there? Um I just, you know, if this is

06:50:39.928 --> 06:50:43.359
the path I want to make sure you're on

06:50:44.999 --> 06:50:47.178
a lawyer and you've been there for a long time, but

06:50:47.619 --> 06:50:55.080
the way that I read um protocol 6.5 0.1 0.1 section

06:50:55.089 --> 06:50:58.208
one says that you're authorized to perform the following

06:50:58.219 --> 06:51:01.389
actions for a limited purpose of security, securely

06:51:01.400 --> 06:51:04.790
operating the ERCOT transmission grid under standards

06:51:04.799 --> 06:51:07.660
specified under NRC standards, the operating ods or

06:51:07.669 --> 06:51:13.290
protocols. Obviously, you're going to 6.5 0.46 0.5

06:51:13.299 --> 06:51:17.269
0.1 0.1 0.4. And

06:51:19.279 --> 06:51:21.279
there is,

06:51:23.839 --> 06:51:31.660
it says consistent with paragraph one E above one E

06:51:31.669 --> 06:51:38.008
above says again, perform additional actions required

06:51:38.019 --> 06:51:41.449
to prevent an imminent emergency condition or to restore

06:51:41.458 --> 06:51:45.320
the ERCOT transmission grid to a secure state in the

06:51:45.330 --> 06:51:48.299
event of an, in the event of an ERCOT transmission

06:51:48.309 --> 06:51:52.820
grid emergency condition. Hm. Aren't all these things

06:51:52.830 --> 06:51:55.910
pointing back to transmission? Obviously, the, the

06:51:55.919 --> 06:52:00.859
primary woodys shaken has said no, but I mean that

06:52:00.869 --> 06:52:03.689
that's, that's what I want to know from y'all. It seems

06:52:03.699 --> 06:52:06.839
to me like they're all saying you can take these actions

06:52:06.848 --> 06:52:10.598
if there's a transmission grid emergency and I just

06:52:10.609 --> 06:52:14.080
don't know how you see it, how you read it differently

06:52:14.508 --> 06:52:18.378
Yeah, so that, that first paragraph gives us broad

06:52:18.389 --> 06:52:20.449
authority to do what it needs to do to preserve the

06:52:20.458 --> 06:52:23.589
integrity of the system. The paragraph four was very

06:52:23.598 --> 06:52:26.820
specific coming out of the 2011 event, which was contract

06:52:26.830 --> 06:52:30.570
for capacity related. When we did that in August of

06:52:30.580 --> 06:52:35.240
2011, we were going out looking for additional capacity

06:52:35.249 --> 06:52:37.689
to get through the rest of that extreme summer and

06:52:37.699 --> 06:52:40.428
the stakeholders wanted us to codify that process by

06:52:40.439 --> 06:52:43.249
putting it in paragraph four. And so that's exactly

06:52:43.258 --> 06:52:47.119
what we did. And so we are using that framework to

06:52:47.128 --> 06:52:49.598
look at the upcoming winter season, seeing that there

06:52:49.609 --> 06:52:53.339
is a risk that we could end up in a severe weather

06:52:53.348 --> 06:52:56.019
event where we have to go into our emergency operations

06:52:56.029 --> 06:52:58.279
to preserve the integrity of the system. And that's

06:52:58.290 --> 06:53:00.240
what we're using that specific authority for.

06:53:06.299 --> 06:53:08.540
You. Don't answer my question in that. But I'd like

06:53:08.549 --> 06:53:12.040
to follow up with you on that to understand the legal

06:53:12.049 --> 06:53:15.178
pinning of why you're doing this. I, I, I'm not saying

06:53:15.189 --> 06:53:18.419
that it's not there. I'm saying that in my reading

06:53:18.428 --> 06:53:23.230
it's ambiguous and that creates, that creates a challenge

06:53:23.240 --> 06:53:27.019
and I just, it makes me fearful that we're doing something

06:53:27.029 --> 06:53:32.958
that's going to be costly and illegal and that, uh

06:53:33.008 --> 06:53:35.928
we're gonna get ourselves in a, in a challenging situation

06:53:35.939 --> 06:53:39.740
if we, when we don't need to. But that's what I'd like

06:53:39.749 --> 06:53:42.269
to follow up on. And I guess what I want to try

06:53:42.279 --> 06:53:46.428
to understand and, and maybe clarify or chat, you can

06:53:46.439 --> 06:53:50.570
clarify this too is, it seemed like this entire process

06:53:50.580 --> 06:53:54.109
started with an RMR for capacity that was reported

06:53:54.119 --> 06:53:57.580
to us that, you know, you're looking at maybe contracting

06:53:57.589 --> 06:54:00.809
some capacity through the RMR process. And I think

06:54:00.820 --> 06:54:04.598
what you're saying, Mr Glotfelty is that the RMR process

06:54:04.609 --> 06:54:09.160
and the protocols is largely targeted towards transmission

06:54:09.169 --> 06:54:12.519
reliability and, and the RMR for capacity is a little

06:54:12.529 --> 06:54:16.499
bit gray in there. Um But then in the last several

06:54:16.508 --> 06:54:23.160
weeks, it's been expanded to section 511 and so sort

06:54:23.169 --> 06:54:26.758
of the two sections of the protocols, those two frameworks

06:54:26.769 --> 06:54:30.410
have been sort of conflated together to now create

06:54:30.419 --> 06:54:33.878
a more expanded capacity procurement. And we're trying

06:54:33.889 --> 06:54:34.740
to understand

06:54:36.389 --> 06:54:39.859
maybe how they work together or, or, or if they are

06:54:39.869 --> 06:54:41.580
intended to work together. Is that what I'm hearing

06:54:41.589 --> 06:54:46.279
from you guys for you Jim. So, so, so what I don't

06:54:46.290 --> 06:54:47.830
know about Commissioner Glotfelty, but

06:54:49.490 --> 06:54:52.080
none of this is being considered in a vacuum. We have

06:54:52.089 --> 06:54:57.519
a statutory framework that we all are trying to operationalize

06:54:58.290 --> 06:55:02.859
and that framework will not bring us resource adequacy

06:55:02.869 --> 06:55:05.678
immediately. And I think that's what ERCOT is attempting

06:55:05.689 --> 06:55:09.139
to do is to try to find capacity, they believe they

06:55:09.150 --> 06:55:13.219
need to meet a scenario based analysis which is the

06:55:13.230 --> 06:55:14.219
Elliott model.

06:55:15.830 --> 06:55:20.799
And, and to do that for this upcoming season where

06:55:20.809 --> 06:55:24.519
I think logic takes us, is that again, we're going

06:55:24.529 --> 06:55:28.839
to run into this next summer as well and then the next

06:55:28.848 --> 06:55:31.869
winter and in the other seasons leading us up to three

06:55:31.878 --> 06:55:35.059
years from now, when eventually the legislative framework

06:55:35.419 --> 06:55:40.878
will bear fruit, hopefully. Yeah. And, and so, yeah

06:55:40.889 --> 06:55:42.779
that, that kind of gets to my question is, is this

06:55:42.790 --> 06:55:47.339
a bridge? It kind of sounds like a bridge and I'm not

06:55:47.348 --> 06:55:49.669
a lawyer, but I, I'm familiar with, you know, that

06:55:49.678 --> 06:55:51.439
Supreme Court ruling, if it looks like a duck and it

06:55:51.449 --> 06:55:54.580
quacks like a duck, it's a duck. But at least there's

06:55:54.589 --> 06:55:57.689
a statutory framework behind that bridge that the legislature

06:55:57.699 --> 06:56:03.900
recognized a need for a bridge. Um, or DC minimums

06:56:03.910 --> 06:56:10.019
are may be uh ineffective given our new posture and

06:56:10.400 --> 06:56:12.650
ancillaries. That's another thing we have to consider

06:56:12.830 --> 06:56:13.348
Um

06:56:15.269 --> 06:56:17.169
So I'm trying to figure out how it all plays together

06:56:17.339 --> 06:56:20.628
Ok. So you're thinking that if it's a bridge then you've

06:56:20.639 --> 06:56:23.339
reduced that from. No, I'm just saying that there's

06:56:23.570 --> 06:56:26.928
a, there's a legislative statutory cap that applies

06:56:26.939 --> 06:56:29.049
to the revenues associated, which gives the market

06:56:29.059 --> 06:56:33.639
some kind of certainty. The industrial's team, at least

06:56:33.650 --> 06:56:35.490
they know what they're dealing with because it's the

06:56:35.499 --> 06:56:39.449
uncertainty that is harmful. It's the fear of the unknown

06:56:39.609 --> 06:56:42.458
and everybody respects you chad, but the definition

06:56:42.469 --> 06:56:44.848
of reasonable lies with you and we don't know what

06:56:44.859 --> 06:56:47.049
that may mean yet. Um,

06:56:48.689 --> 06:56:50.790
and I'm, I'm trying to get my arms around that too

06:56:52.708 --> 06:56:59.449
good point. And for me, I'm just not, I don't, haven't

06:56:59.458 --> 06:57:03.049
been here long enough. I don't know, I don't know the

06:57:03.059 --> 06:57:05.378
legal weight behind these protocols.

06:57:07.359 --> 06:57:10.458
We now have requirements that we have to approve all

06:57:10.469 --> 06:57:14.208
these changes and I just don't understand

06:57:16.969 --> 06:57:17.889
uh

06:57:20.359 --> 06:57:22.619
why. Um

06:57:24.799 --> 06:57:27.848
I don't understand how the authority is derived from

06:57:27.859 --> 06:57:29.820
a protocol chad. You've said that a number of times

06:57:29.839 --> 06:57:32.189
Well, it's in the protocol, but I don't understand

06:57:32.199 --> 06:57:35.309
what the legal pinning of PURA is for the protocol

06:57:35.559 --> 06:57:39.540
for the protocol that you're pointing to 39 151 reliability

06:57:40.139 --> 06:57:42.869
So, and that may, that may be it. And I just need

06:57:42.878 --> 06:57:47.669
to educate myself more, but I don't want to be a naysayer

06:57:47.708 --> 06:57:50.469
I want to be a, I want to understand it, but I

06:57:50.480 --> 06:57:54.089
also want to be one that I, I um y'all heard me

06:57:54.098 --> 06:57:58.609
talk before. I'm very hesitant of an RT O or an is

06:57:58.619 --> 06:58:02.900
Os mission creep mission creep in in other regions

06:58:02.910 --> 06:58:06.439
is a whole lot more than it is here in ERCOT. Um

06:58:06.580 --> 06:58:12.878
But um the goal was when ERCOT was created open access

06:58:12.889 --> 06:58:15.799
ensure open access to the transmission system. So the

06:58:15.809 --> 06:58:18.559
market ran efficiently and reliably

06:58:20.258 --> 06:58:23.639
but not to deal with every single resource on the system

06:58:23.650 --> 06:58:26.650
That's what the market's goal was. So I'm just, I'm

06:58:26.660 --> 06:58:30.758
in this kind of straddling some of the old world and

06:58:30.769 --> 06:58:34.059
the new world. And I don't know where I come down on

06:58:34.070 --> 06:58:37.859
this with this statutory framework of what the protocol

06:58:37.869 --> 06:58:41.029
is, costs are going to be difficult to digest no matter

06:58:41.040 --> 06:58:44.730
what that is going to be a controversial topic. Reliability

06:58:44.740 --> 06:58:46.410
is not cheap. Everybody knows that.

06:58:48.089 --> 06:58:51.559
And we don't know even if we'll get the, the outcomes

06:58:51.570 --> 06:58:53.719
that are desired on the part of ERCOT, we don't know

06:58:53.730 --> 06:58:56.230
how the market will respond. Ultimately, there's unknowns

06:58:56.240 --> 06:59:03.449
there. Um You know, and, and so the math is, I'm unsure

06:59:03.458 --> 06:59:10.699
of even now is, is the magnitude of cost based on 3000

06:59:10.708 --> 06:59:15.669
megawatts at 5000 high cap um based on a three day

06:59:15.839 --> 06:59:19.469
because that's the maximum amount you can award to

06:59:19.480 --> 06:59:27.660
any one dr asset times 24 hours that comes out to $1.08

06:59:27.669 --> 06:59:31.928
billion ok? That's 3000 megawatts if that gets you

06:59:31.939 --> 06:59:34.249
what you need to

06:59:35.969 --> 06:59:38.669
again the statutory tie. And I'm trying to figure out

06:59:38.678 --> 06:59:44.150
how to frame this among the rules based system that

06:59:44.160 --> 06:59:49.469
we have, which the protocol is in and statute tangentially

06:59:49.480 --> 06:59:53.330
speaks to. I'm sure Katie and everybody else is appalled

06:59:53.339 --> 06:59:58.378
but we're, this does eventually seek up sync up. So

06:59:58.449 --> 07:00:01.299
Mister McAdams, when you're, I think trying to interpret

07:00:01.309 --> 07:00:05.029
this as a potential bridge that would contemplate using

07:00:05.040 --> 07:00:08.089
this for the next three years. Well, I'm saying that

07:00:08.708 --> 07:00:11.178
once they solve the reliability condition for this

07:00:11.189 --> 07:00:14.919
winter, given extreme weather circumstances, they're

07:00:14.928 --> 07:00:16.809
going to have to solve the reliability condition with

07:00:16.820 --> 07:00:20.458
demand growth for the next summer. And you have to

07:00:20.469 --> 07:00:24.609
recognize that you'd be foolish not to. How do they

07:00:24.619 --> 07:00:28.708
do that with, without um again, the legislative framework

07:00:29.660 --> 07:00:31.928
producing the desired result, which is going to take

07:00:31.939 --> 07:00:32.449
some time,

07:00:34.169 --> 07:00:36.330
these new megawatts of generation are just going to

07:00:36.339 --> 07:00:41.230
appear and materialize. So I, I guess I was kind of

07:00:41.570 --> 07:00:44.029
I wanna kind of put this in, maybe try to put in

07:00:44.040 --> 07:00:48.109
perspective from, from my lenses here or my lens it

07:00:48.119 --> 07:00:52.299
So the protocol section you're talking about and, and

07:00:52.309 --> 07:00:54.790
sort of what I've seen in the different iterations

07:00:54.799 --> 07:00:58.049
of more of the more of um you know, the, the Pete's

07:00:58.490 --> 07:01:07.519
um presentation that we reviewed has a 17.89% um risk

07:01:07.529 --> 07:01:11.098
of being less than 2500. However, the presentation

07:01:11.109 --> 07:01:17.619
that ERCOT just provided to us has 19.909%. So there's

07:01:17.628 --> 07:01:20.040
like a 2% difference. So I'd like to understand that

07:01:20.049 --> 07:01:21.910
And if you have any additional information you can

07:01:21.928 --> 07:01:25.589
file or provide to know why it's 2% higher from one

07:01:25.598 --> 07:01:26.969
presentation to the next

07:01:37.059 --> 07:01:40.869
excuse me, got a frog in my throat. So uh Pete Warnken

07:01:41.070 --> 07:01:46.320
ERCOT, uh so the model that was used to support the

07:01:46.330 --> 07:01:50.958
capacity RFP was a seasonal model. So that incorporates

07:01:50.969 --> 07:01:53.359
information throughout the three months of the winter

07:01:53.369 --> 07:01:56.939
season. The Mora report is just for a single month

07:01:56.949 --> 07:02:02.160
for December. So January is more risky than December

07:02:02.169 --> 07:02:05.919
Again, you got higher loads, um, you know, other factors

07:02:05.928 --> 07:02:09.570
as well. So that's where you get that, that 2% difference

07:02:09.719 --> 07:02:13.499
It's a seasonal view versus a monthly view. Ok. So

07:02:13.508 --> 07:02:16.040
this is what, what is, what we're gonna see in January

07:02:16.559 --> 07:02:20.410
Well, you're gonna see something close to that. Ok

07:02:20.490 --> 07:02:23.029
Yeah. Yeah, I mean, that's the thing, right? We're

07:02:23.040 --> 07:02:25.199
we're looking at percentages right now. We have a Mora

07:02:25.208 --> 07:02:28.848
that says 17.89 that we've gotten a report on, but

07:02:28.859 --> 07:02:31.290
we don't have all the information on January and we're

07:02:31.299 --> 07:02:33.529
looking at a bunch of risk levels and trying to determine

07:02:33.540 --> 07:02:36.650
what makes sense from a lot of different angles. So

07:02:36.660 --> 07:02:40.820
um, and, and, and as I look at the winter storm Elliott

07:02:40.830 --> 07:02:45.730
chart, um, the high, the hour of highest reliability

07:02:45.740 --> 07:02:48.769
risk is at 8 a.m. Arguably, if you want to say, if

07:02:48.779 --> 07:02:52.458
a risk is greater than 10% then you can count the 10.882

07:02:52.469 --> 07:02:56.779
But Oliver Cot's presentations has focused on 8 a.m.

07:02:56.790 --> 07:03:00.439
being the hour of highest reliability risk. And so

07:03:00.589 --> 07:03:04.928
I'm trying to understand because even in the winter

07:03:04.939 --> 07:03:08.339
as we all know the ramp up of solar in the morning

07:03:08.348 --> 07:03:11.490
in the 8 a.m. high risk hour, but then in the evening

07:03:11.499 --> 07:03:14.580
the ramp down is not really showing any kind of risk

07:03:14.820 --> 07:03:20.320
in your chart. But yet the RP is for a duration of

07:03:20.330 --> 07:03:24.458
minimum of six hours and up to 24 7 availability. So

07:03:24.469 --> 07:03:28.109
I'm trying to marry up how, you know what the thinking

07:03:28.119 --> 07:03:31.080
is here with the hour of highest reliability risk at

07:03:31.089 --> 07:03:36.419
8 a.m. with an RP that is seeking to reduce that risk

07:03:36.428 --> 07:03:39.189
below 10%. And that's the 3000,

07:03:40.749 --> 07:03:43.919
but we're talking about one hour. And so how do we

07:03:43.928 --> 07:03:46.889
get to 24 7 availability in all these blocks of time

07:03:46.900 --> 07:03:52.119
then in the morning, in the night, all day? Well, again

07:03:52.128 --> 07:03:54.830
from a risk perspective, you know, you're focusing

07:03:54.839 --> 07:03:58.650
on that 8 a.m. Now, again, the storm could hit at other

07:03:58.660 --> 07:04:01.619
times of the day, for example, um again, you could

07:04:01.628 --> 07:04:04.458
have, you know, severe or high amount of uh thermal

07:04:04.469 --> 07:04:08.369
outages that are unexpected. So again, 8:08 a.m. is

07:04:08.378 --> 07:04:11.540
the focus because, you know, based on the risk assessment

07:04:12.089 --> 07:04:15.150
that's where that's the hour that is most risky. But

07:04:15.529 --> 07:04:18.928
again, given a winter storm event, you could see risk

07:04:18.939 --> 07:04:21.080
at any time of the day and there is an uptick in

07:04:21.089 --> 07:04:23.580
risk in the early evening when that solar drop off

07:04:23.589 --> 07:04:26.969
happens. But, but your probability analysis that solely

07:04:26.980 --> 07:04:30.889
focused on the winter storm shows, I mean, from 7 to

07:04:30.900 --> 07:04:38.008
10, you're at, you know, 0.87% 0.11 0.542 0.182%. I

07:04:38.019 --> 07:04:41.359
mean, you're not showing any risk except for that one

07:04:41.369 --> 07:04:45.049
hour. Um So that's what I'm trying to understand from

07:04:45.059 --> 07:04:48.449
from a sort of parameter standpoint. And that would

07:04:48.458 --> 07:04:52.240
lead into sort of maybe the broader cost perspective

07:04:52.249 --> 07:04:53.508
that you guys are bringing up.

07:04:55.089 --> 07:04:58.400
So I'm just trying to understand how,

07:05:00.139 --> 07:05:03.939
how this is all sort of, I guess morphed into this

07:05:03.949 --> 07:05:07.040
sort of broader approach.

07:05:08.869 --> 07:05:14.019
Well, well, OK, so one thought on this and, and Woody

07:05:14.029 --> 07:05:18.139
raised his hand but couple questions, there's the need

07:05:18.150 --> 07:05:21.928
case which that's what your questions are kind of pointing

07:05:21.939 --> 07:05:28.299
to. But two under, under the rules based strategy that

07:05:28.320 --> 07:05:34.949
ERCOT is pursuing, which is the RMR for capacity and

07:05:34.958 --> 07:05:41.419
the protocol 6.5 0.1 0.1 they can do this anyway. And

07:05:41.439 --> 07:05:45.249
ERCOT is choosing, they believe they have a reliability

07:05:45.258 --> 07:05:49.240
condition that that could be experienced in the upcoming

07:05:49.249 --> 07:05:52.889
season. And so they are pursuing that protocol. I don't

07:05:52.919 --> 07:05:56.169
think, I don't think they're asking and I'm not putting

07:05:56.178 --> 07:05:58.609
words in your mouth, but this is, this is a work session

07:05:58.619 --> 07:06:01.508
and we're not making any decisions here, but we're

07:06:01.519 --> 07:06:02.269
working it out

07:06:03.820 --> 07:06:07.119
with that in mind. We have to consider. All right,

07:06:07.128 --> 07:06:10.848
how do we harmonize what's happening here with, with

07:06:10.859 --> 07:06:14.359
what this commission can control and try to harmonize

07:06:14.369 --> 07:06:17.589
our own mission sets, which is also affordability and

07:06:17.598 --> 07:06:21.499
cost containment for the system with the reliability

07:06:21.508 --> 07:06:27.519
objectives of, of ERCOT and this new policy, not new

07:06:27.529 --> 07:06:33.369
policy, old policy that's being operationalized. So

07:06:33.749 --> 07:06:36.139
that's what I'm trying to figure out is like, how do

07:06:36.150 --> 07:06:40.369
how do we shape this? Now? If the debate is the, the

07:06:40.378 --> 07:06:42.740
need case may not be

07:06:44.570 --> 07:06:47.869
present. That's another question. Well, the, the, the

07:06:47.878 --> 07:06:50.469
ship has obviously left the station, but I'm just trying

07:06:50.480 --> 07:06:52.428
to figure out as we look at what,

07:06:54.150 --> 07:06:58.189
what um how we, how we size this, right? How we sizing

07:06:58.199 --> 07:07:03.549
it a 3000. But what are some, you know, what, what

07:07:03.559 --> 07:07:06.040
are the parameters associated in the RP that, that

07:07:06.049 --> 07:07:10.040
are driving sort of this, this undefined cost, right

07:07:10.049 --> 07:07:12.669
One of it is that we're gonna procure 3000 megawatts

07:07:12.678 --> 07:07:15.580
that could be available in the morning. Um Well, all

07:07:15.589 --> 07:07:19.389
day in the morning, at night, morning and night. So

07:07:19.400 --> 07:07:21.490
I'm just trying to figure out like what, where the

07:07:21.499 --> 07:07:25.609
sensitivities are that we can ensure liability as probabilistic

07:07:25.619 --> 07:07:29.309
um analysis shows for defined times that we've identified

07:07:29.699 --> 07:07:33.290
and the January Mora hasn't come out. And so it's hard

07:07:33.299 --> 07:07:36.230
to kind of see that far because we have, we don't have

07:07:36.240 --> 07:07:38.990
an hour breakdown and of all the hours like he did

07:07:38.999 --> 07:07:41.389
for the December Maura. So I'm trying to define the

07:07:41.400 --> 07:07:45.949
risk more narrowly, more targeted so that we can procure

07:07:45.969 --> 07:07:50.740
in a more targeted manner. Um, so that we can, you

07:07:50.749 --> 07:07:53.128
know, we, we can contain costs here because right now

07:07:53.139 --> 07:07:55.820
we're kind of in the dark, right? I mean, we don't

07:07:55.830 --> 07:07:59.428
know exactly how much these capacity contracts are

07:07:59.439 --> 07:08:01.779
gonna cost. I mean, I, I, I'm trying to understand

07:08:01.790 --> 07:08:04.809
even sort of the pieces of it. Right. So you have,

07:08:04.848 --> 07:08:05.559
um

07:08:07.150 --> 07:08:11.628
a daily standby payment um and incentive factor that

07:08:11.639 --> 07:08:13.910
could be greater than 10% you have an availability

07:08:13.919 --> 07:08:15.980
factor, there's an energy payment that includes fuel

07:08:15.990 --> 07:08:19.240
costs based on FIP plus a re a fuel ladder that's provided

07:08:19.249 --> 07:08:22.410
by a resource entity. And ERCOT is going to evaluate

07:08:22.419 --> 07:08:27.309
all these bids and offers slash offers under criteria

07:08:27.320 --> 07:08:29.779
that what resources provide the greatest reliability

07:08:29.790 --> 07:08:30.439
benefit.

07:08:32.309 --> 07:08:35.369
But what's the criteria to define that even so that

07:08:35.378 --> 07:08:38.348
we have some kind of criteria where we are just not

07:08:38.359 --> 07:08:40.269
kind of, I mean,

07:08:43.549 --> 07:08:46.290
I mean, going off with, we don't have any kind of idea

07:08:46.299 --> 07:08:48.199
of what we're facing here. You're getting an emergency

07:08:48.208 --> 07:08:51.708
alert right now. Just so, you know, so understanding

07:08:51.719 --> 07:08:53.980
the different pieces that I just named might be helpful

07:08:53.990 --> 07:08:56.689
and how they interact with each other and maybe some

07:08:56.699 --> 07:08:59.428
criteria as to how you're gonna evaluate those and

07:08:59.439 --> 07:09:01.628
what are thresholds? I mean, there was a question of

07:09:01.779 --> 07:09:05.128
10%. It can be greater than that. Well, I mean, that

07:09:05.139 --> 07:09:07.708
could be anything. So and I know it's based on the

07:09:07.719 --> 07:09:11.339
offers, but like what are there any parameters, any

07:09:11.348 --> 07:09:15.779
guard rails that we can expect that will help us understand

07:09:15.790 --> 07:09:19.419
what we're facing? So they've already said that they

07:09:19.428 --> 07:09:22.299
will consider a reasonable test in terms of rejecting

07:09:22.309 --> 07:09:24.910
offers and, and they have a path forward on. Well,

07:09:25.160 --> 07:09:29.928
I I understand the concern but, but they have the existing

07:09:29.939 --> 07:09:34.230
dr programs, they're already following a decision-making

07:09:34.240 --> 07:09:38.378
process that establishes precedents on how they reject

07:09:39.428 --> 07:09:43.799
inappropriate offers. I mean that that's what mark

07:09:43.809 --> 07:09:47.109
was pointing to earlier is that some of these offers

07:09:47.208 --> 07:09:50.559
are out of alignment with the rest of the acceptable

07:09:50.570 --> 07:09:53.240
range and therefore they are not accepted and they

07:09:53.249 --> 07:09:54.439
are not awarded

07:09:56.169 --> 07:10:00.519
part of a demand response service. So it, it seems

07:10:00.529 --> 07:10:03.540
like they have a path that they would follow. And what

07:10:03.549 --> 07:10:06.740
I'm trying to say is there's a maximum range under

07:10:06.749 --> 07:10:10.939
statute that could, that could offer the boundaries

07:10:10.999 --> 07:10:14.939
of this capacity, procurement. And then what part of

07:10:14.999 --> 07:10:18.269
my interest in coming to this work session was to ask

07:10:18.279 --> 07:10:21.589
staff and potentially instruction instruct our staff

07:10:21.598 --> 07:10:25.059
commission staff before the November 2nd open meeting

07:10:25.208 --> 07:10:28.830
is to work on the potential parameters of a budget

07:10:29.749 --> 07:10:32.990
that, that this program could follow. And, and I don't

07:10:32.999 --> 07:10:37.809
believe anybody rejects the premise that a budget could

07:10:37.820 --> 07:10:41.969
be acceptable depending on how it was structured. I

07:10:41.980 --> 07:10:44.869
realize er staff did not want to impose a budget right

07:10:44.878 --> 07:10:48.790
now before the outcome of the auctions because they

07:10:48.799 --> 07:10:52.049
wanted to know the universe of potential megawatts

07:10:52.059 --> 07:10:55.758
in demand and generation that was out there. But for

07:10:55.769 --> 07:10:57.820
the part of the commission, it does seem appropriate

07:10:57.830 --> 07:11:00.080
and we have done this on other programs, firm fuel

07:11:00.089 --> 07:11:01.150
supply service

07:11:02.839 --> 07:11:09.279
in in S and so I I think that's reasonable as a

07:11:09.290 --> 07:11:12.779
request that that by November 2nd, we could have something

07:11:12.790 --> 07:11:16.469
to consider and ERCOT could consider that as guidance

07:11:16.480 --> 07:11:21.230
moving forward. And would that budget be set on a collaborative

07:11:21.240 --> 07:11:24.609
basis with Irt and commission staff and maybe independent

07:11:24.619 --> 07:11:27.089
review of some sort? I think it's absolutely it would

07:11:27.098 --> 07:11:29.490
it would necessitate that collaboration. But

07:11:31.070 --> 07:11:33.980
well, for me, I think this is about, it's about managing

07:11:33.990 --> 07:11:38.740
change and about it's about managing risk. And we know

07:11:38.749 --> 07:11:41.910
that the resource mix has changed significantly. We

07:11:41.919 --> 07:11:46.160
know we have growth, we know we're entering a time

07:11:46.169 --> 07:11:49.040
of the year and, and forecast as good as we can and

07:11:49.049 --> 07:11:51.359
the best tools that we have and the best assumption

07:11:51.369 --> 07:11:53.708
we have and the best professional judgment that we

07:11:53.719 --> 07:11:57.570
have, we still are trying at the end of the day to

07:11:57.580 --> 07:12:00.029
manage that risk. And so to the extent that we have

07:12:00.040 --> 07:12:03.109
flexibility to the extent that we have as many tools

07:12:03.119 --> 07:12:06.150
as we can. Because quite frankly, we're losing tools

07:12:06.369 --> 07:12:09.240
we need to be able to replace them. I think with others

07:12:09.499 --> 07:12:13.369
Um you know, actually going out and seeing what is

07:12:13.378 --> 07:12:18.029
available uh in, in my mind is kind of a prudent step

07:12:18.230 --> 07:12:22.859
And I just wonder what is ERCOT s, you know, view on

07:12:22.869 --> 07:12:26.339
that in terms of, you know, how do you kind of see

07:12:26.348 --> 07:12:29.208
this unfolding? And um

07:12:30.869 --> 07:12:33.730
you know, how we can kind of against kind of moving

07:12:33.740 --> 07:12:38.249
forward, make sure we continue to have the, the flexibility

07:12:38.258 --> 07:12:41.160
because the public absolutely does have an expectation

07:12:41.330 --> 07:12:45.178
that reliability is number one. And we do talk about

07:12:45.189 --> 07:12:48.559
all the cost of this service. But as you know, there

07:12:48.570 --> 07:12:52.378
are many more costs undefined in terms of what would

07:12:52.389 --> 07:12:55.839
happen if, if we get into a situation where we're not

07:12:55.848 --> 07:13:00.730
able to manage it. And so, I mean, what, what is ERCOT

07:13:00.740 --> 07:13:02.820
thought going forward in terms of, you know, based

07:13:02.830 --> 07:13:05.019
on some of the things that we've kind of talked about

07:13:05.029 --> 07:13:07.258
here. So obviously, we welcome any guidance from the

07:13:07.269 --> 07:13:08.910
commission that they want to offer as we go through

07:13:08.919 --> 07:13:13.449
this RFP, you know, we saw this as an opportunity again

07:13:13.458 --> 07:13:15.958
I think I've said this before that to really see how

07:13:15.969 --> 07:13:20.139
the demand side can step up and offer in what their

07:13:20.150 --> 07:13:23.359
capability is under a, what I would say is a light

07:13:23.369 --> 07:13:26.320
touch for the demand side to participate for this upcoming

07:13:26.330 --> 07:13:30.070
winter. And we think there's a great opportunity. We've

07:13:30.080 --> 07:13:33.178
heard a lot of that today for entities to come forward

07:13:33.189 --> 07:13:35.900
and see if they can develop a program that will provide

07:13:35.910 --> 07:13:38.980
reliable service during the upcoming winter season

07:13:39.219 --> 07:13:42.098
We're well aware of all the financial guard rails that

07:13:42.109 --> 07:13:44.928
have been set through these other programs. PRS farm

07:13:44.939 --> 07:13:48.619
fuel the system wide offer cap those will all be part

07:13:48.628 --> 07:13:51.678
of the consideration as we go through and evaluate

07:13:51.689 --> 07:13:55.570
offers. We did not want to come out with a specific

07:13:55.678 --> 07:13:59.080
offer criteria because what usually happens in that

07:13:59.089 --> 07:14:02.439
situation is people go right to the top and so we want

07:14:02.449 --> 07:14:06.109
everyone to consider what their true cost is and then

07:14:06.119 --> 07:14:10.359
submit that. And we will go through a reasonable evaluation

07:14:10.369 --> 07:14:13.279
based upon all the existing guardrails that exist already

07:14:13.290 --> 07:14:15.939
in this market to determine what is reasonable and

07:14:15.949 --> 07:14:18.219
fair for the reliable service that we're going to get

07:14:18.848 --> 07:14:22.609
And so that was the policy decision made by the executive

07:14:22.619 --> 07:14:24.869
management when we came out with this RFP.

07:14:27.598 --> 07:14:29.508
But if the commission wants to offer guidance on that

07:14:29.519 --> 07:14:32.749
we welcome that as we move forward through this. I

07:14:32.758 --> 07:14:35.389
mean, look, I I understand that you guys are trying

07:14:35.400 --> 07:14:37.889
to ensure reliability. We all want reliability, Mister

07:14:38.029 --> 07:14:43.128
Jackson Jackson, I mean, we, we do right. And um but

07:14:43.139 --> 07:14:45.559
it's tough, right? Because affordability is, is right

07:14:45.570 --> 07:14:48.820
there right behind it. And, and it's hard for us, at

07:14:48.830 --> 07:14:51.499
least for I can say for myself is that, you know, at

07:14:51.508 --> 07:14:54.730
the end of the day, we, the commission are gonna be

07:14:54.740 --> 07:14:57.559
probably held responsible for the cost that is imposed

07:14:57.570 --> 07:15:01.359
on uh on, you know, the the ratepayers for, for these

07:15:01.369 --> 07:15:04.469
costs, especially if you know, ultimately, the L CS

07:15:04.480 --> 07:15:06.749
want to pass them through on electricity bills. So

07:15:07.230 --> 07:15:10.570
ERCOT S mission isn't to look out for consumer costs

07:15:10.580 --> 07:15:12.719
and, and that's not y'all's mission, that's our mission

07:15:12.969 --> 07:15:16.119
And so how can we work together to ensure that there

07:15:16.128 --> 07:15:20.059
are some kind of guard rails in there, some some parameters

07:15:20.070 --> 07:15:23.519
that will he help us feel comfortable um that are consistent

07:15:23.529 --> 07:15:25.799
with other existing products? And that's what, you

07:15:25.809 --> 07:15:27.480
know, I think Commissioner McAdams raised the budget

07:15:27.490 --> 07:15:30.730
cap because otherwise we're kind of just left out in

07:15:30.740 --> 07:15:34.660
the open and, and that's a difficult place for, for

07:15:34.669 --> 07:15:37.480
us to be in. And so I hope that you guys can

07:15:37.490 --> 07:15:40.598
recognize that I don't know what the number is. I mean

07:15:40.609 --> 07:15:43.589
I mean, I don't want to sit here and you know, fire

07:15:43.598 --> 07:15:46.719
off a number, but there's gotta be some evaluation

07:15:46.730 --> 07:15:49.309
and understanding also, you know, the generation component

07:15:49.320 --> 07:15:51.049
of it is kind of, you know, I don't know how that's

07:15:51.059 --> 07:15:55.089
looking, but a demand response focus may end up being

07:15:55.098 --> 07:15:58.029
what ultimately happens. But in your own example, on

07:15:58.040 --> 07:16:02.740
the Q and A for uh 10 Megawatt dr resource at 1500

07:16:02.749 --> 07:16:06.230
megawatts, I mean, for 10 megawatts, it could be 18.7

07:16:06.240 --> 07:16:09.428
million and be easily into the billions of that. I

07:16:09.439 --> 07:16:11.949
mean, so demand response could also be expensive. So

07:16:11.958 --> 07:16:15.339
I I'm just trying to figure out what can we do to

07:16:15.348 --> 07:16:18.990
give you all flexibility to accomplish your mission

07:16:18.999 --> 07:16:22.990
but also to ensure from our standpoint, from the commission

07:16:22.999 --> 07:16:26.639
standpoint that we are being good stewards of, of the

07:16:26.650 --> 07:16:30.839
public's money at a time where people do care about

07:16:30.848 --> 07:16:35.439
cost and, and, um, and, and figure out what parameters

07:16:35.449 --> 07:16:37.639
would, would be helpful that we so that we can all

07:16:37.650 --> 07:16:41.059
accomplish our mission here. That, that's, that's really

07:16:41.070 --> 07:16:45.980
my perspective. It's well founded. Absolutely. Um,

07:16:50.178 --> 07:16:54.480
pick. But it, it, it, it does not change the fact that

07:16:54.928 --> 07:17:01.169
Ct's Protocol is, is, is alive. They, they are uh they

07:17:01.178 --> 07:17:06.749
have built a framework um mostly around the protocol

07:17:07.059 --> 07:17:12.160
uh with some changes nuances to it. They're asserting

07:17:12.169 --> 07:17:15.269
that. I mean, that that is, and that is their prerogative

07:17:15.279 --> 07:17:19.519
under that protocol which a commission in 2011 approved

07:17:20.019 --> 07:17:23.320
I think they approved it. Right, Chad. So the process

07:17:23.330 --> 07:17:25.540
back then was the board approved it and we submitted

07:17:25.549 --> 07:17:28.199
it to the commission, but it was no formal approval

07:17:28.208 --> 07:17:30.740
by the commission. But that's how that process has

07:17:30.749 --> 07:17:33.758
been all the way up until Senate Bill two. So that's

07:17:33.769 --> 07:17:36.928
what I'm saying is that has been affirmed by the public

07:17:36.939 --> 07:17:40.949
utility of Commission in some form or fashion. And

07:17:41.990 --> 07:17:44.969
and so I'm just trying to figure out how we can harmonize

07:17:44.980 --> 07:17:48.189
our missions here. Exactly. And, and I think you can

07:17:48.199 --> 07:17:51.230
see the chat earlier that ultimately when this, this

07:17:51.240 --> 07:17:53.359
um procurement happens and you can look back and do

07:17:53.369 --> 07:17:57.008
the lessons learned. Um if we plan to use this in the

07:17:57.019 --> 07:18:00.378
future, then we can um develop a more robust, you know

07:18:00.389 --> 07:18:03.080
kind of framework that, you know, would involve commission

07:18:03.089 --> 07:18:06.650
involvement and um through, you know, puc role or protocol

07:18:06.660 --> 07:18:09.949
change and protocol changes that are right now that

07:18:09.958 --> 07:18:14.070
protocol E exists and you guys are exercising it um

07:18:14.779 --> 07:18:18.958
in, but I think a broader framework after this procurement

07:18:18.969 --> 07:18:22.389
um that's, you know, more robust and embedded, I think

07:18:22.400 --> 07:18:25.900
would be the long term solution if we intend to use

07:18:25.910 --> 07:18:28.650
the framework again. And I think I agree, I mean, just

07:18:28.660 --> 07:18:31.219
like we did in 2011 where we created this framework

07:18:31.230 --> 07:18:33.790
now that we're using it, we will learn a lot from it

07:18:37.150 --> 07:18:38.839
But, but I think one of the things that we kind of

07:18:38.848 --> 07:18:42.249
talked about today all day long is, you know, this

07:18:42.258 --> 07:18:46.189
this focus on the demand side of the equation. And

07:18:46.199 --> 07:18:49.258
so, you know, we've had lots and lots of effort and

07:18:49.269 --> 07:18:52.150
good effort on the supply side and we're really just

07:18:52.160 --> 07:18:55.559
kind of ruling maybe for the first time, really kind

07:18:55.570 --> 07:18:58.749
of putting a, a hard focus on the demand side. And

07:18:58.758 --> 07:19:01.820
so I think to you to your point, you know, you, you

07:19:01.830 --> 07:19:04.160
you want to kind of see what's out there, you want

07:19:04.169 --> 07:19:06.769
to maintain that flexibility. I think you mentioned

07:19:06.779 --> 07:19:08.799
that you didn't, you know, you don't want to put something

07:19:08.809 --> 07:19:11.199
out there as a guard wheel and you could have gotten

07:19:11.208 --> 07:19:14.669
it for a much lower cost. Um and I, and I think

07:19:14.678 --> 07:19:17.540
it's really, it's a different, it's a different type

07:19:17.549 --> 07:19:21.499
of response than what we saw on just the supply side

07:19:21.848 --> 07:19:25.769
um solutions. And so, you know, I, I would think kind

07:19:25.779 --> 07:19:29.240
of going forward, we want to keep that in mind. And

07:19:29.249 --> 07:19:32.160
um, I think, you know, to your point going back, you

07:19:32.169 --> 07:19:35.799
know, after this, you know, this initial season, taking

07:19:35.809 --> 07:19:38.339
a good look at it, making sure we've got those protocol

07:19:38.348 --> 07:19:42.480
calls soundly in place. But, um, you know, really think

07:19:42.490 --> 07:19:43.999
about, you know,

07:19:45.570 --> 07:19:48.258
giving this kind of like the absolute best chance that

07:19:48.269 --> 07:19:51.859
it could have. Also recognizing that, you know, there's

07:19:52.290 --> 07:19:55.359
there's, there's not a whole lot of, more of other

07:19:55.369 --> 07:19:57.529
options that are out there right now. And we do know

07:19:57.540 --> 07:20:00.059
that we've got growth coming and we do know that we

07:20:00.070 --> 07:20:03.269
have, um, you know, challenges with the coming weather

07:20:03.320 --> 07:20:04.730
with the winter weather coming

07:20:07.878 --> 07:20:08.660
first. What do you think?

07:20:12.150 --> 07:20:12.820
Um,

07:20:17.040 --> 07:20:18.809
you know, I guess my honest

07:20:22.769 --> 07:20:26.439
conflict internally is that, you know, the state has

07:20:26.449 --> 07:20:29.249
historically, you know, time after time after time

07:20:29.258 --> 07:20:32.378
after time said, don't do a capacity market and we're

07:20:32.389 --> 07:20:35.769
not doing this isn't a full capacity market and we

07:20:35.779 --> 07:20:38.219
went through market design changes for two years to

07:20:38.230 --> 07:20:41.449
try to solve the problem. And, you know, and then the

07:20:41.458 --> 07:20:44.389
legislature spoke again on that and the governor and

07:20:44.400 --> 07:20:46.919
and then we just, this kind of comes out of left field

07:20:46.928 --> 07:20:51.378
and it's just a I don't know. That's what I, that's

07:20:51.389 --> 07:20:53.779
what I struggle with on it because I don't, we also

07:20:53.790 --> 07:20:57.469
heard today that there are thousands of megawatts that

07:20:57.480 --> 07:21:00.749
are out there that have the ability to get into the

07:21:00.758 --> 07:21:04.650
system, but haven't found their way into the system

07:21:04.660 --> 07:21:05.708
yet. And

07:21:07.339 --> 07:21:11.119
I think we could easily find more than 3000 megawatts

07:21:11.580 --> 07:21:16.508
if we really tried to solve those other market problems

07:21:16.559 --> 07:21:20.820
those congestion problems, those other issues. And

07:21:20.839 --> 07:21:27.199
I don't know if that's a, that to me is a better

07:21:27.208 --> 07:21:32.769
way to utilize the market than it is to, to do something

07:21:32.779 --> 07:21:36.559
like this. That's just my gut. But I,

07:21:38.708 --> 07:21:43.070
you know, it's, it's, there's also a situation where

07:21:43.080 --> 07:21:47.939
I see, you know, I gave the, the transmission and the

07:21:47.949 --> 07:21:51.758
TDUs a hard time about mobile gen it's pretty hard

07:21:51.769 --> 07:21:55.458
for them to not buy it when it's sitting in there in

07:21:55.469 --> 07:21:58.969
the law that says you have the ability to do this and

07:21:58.980 --> 07:22:02.389
then there's an outage and they get dragged up to the

07:22:02.400 --> 07:22:04.139
Capitol and says, well, why the hell didn't you do

07:22:04.150 --> 07:22:11.299
this? So it's a very hard situation. I think my best

07:22:11.309 --> 07:22:15.619
hope would be that we get zero megawatts on the generation

07:22:15.628 --> 07:22:20.008
side and we get a few 1000 on the demand response side

07:22:20.320 --> 07:22:25.348
And, and that becomes the formation of a true demand

07:22:25.359 --> 07:22:27.730
response market where everybody can play into that

07:22:27.740 --> 07:22:31.839
market where we get the utilities out of demand response

07:22:31.848 --> 07:22:34.529
and we put them into energy efficiency. And then all

07:22:34.540 --> 07:22:38.359
of these programs really morph into the demand side

07:22:38.369 --> 07:22:42.580
function, not as a capacity market but as

07:22:44.469 --> 07:22:48.839
a a market function that can be utilized every day

07:22:48.848 --> 07:22:51.529
not just during an emergency. So do you think that

07:22:51.540 --> 07:22:53.889
maybe something like this as proposed, could kind of

07:22:53.900 --> 07:22:59.939
kickstart that process kind of whether I, whether it

07:22:59.949 --> 07:23:02.330
does or not? I think it, well, whether I want it to

07:23:02.339 --> 07:23:04.969
or not, I think it does because I think it started

07:23:04.980 --> 07:23:07.830
the discussion about it. It started the discussion

07:23:07.839 --> 07:23:11.089
about all the megawatts. Can they actually participate

07:23:11.389 --> 07:23:14.859
Will you not mothball units? I don't think it solves

07:23:14.869 --> 07:23:20.708
the the older generation kind of a backstop, you know

07:23:20.900 --> 07:23:24.609
process that Commissioner Cobos and I support. But

07:23:26.859 --> 07:23:29.128
you know, I think we're going to have to see, you know

07:23:29.139 --> 07:23:29.598
I'm

07:23:32.740 --> 07:23:35.400
maybe I'm cautiously optimistic but I, I don't know

07:23:35.410 --> 07:23:39.589
I need to keep thinking about it and see where it goes

07:23:40.758 --> 07:23:43.949
Really, really, I think my biggest, you know, concern

07:23:43.958 --> 07:23:49.449
right now is really understanding. I accept that the

07:23:49.458 --> 07:23:56.040
protocols have been approved. I just, I don't understand

07:23:57.508 --> 07:24:01.008
the language

07:24:02.969 --> 07:24:06.439
beyond the beyond transmission emergencies. I mean

07:24:06.449 --> 07:24:12.240
I think that's so, you know, my experience with RT

07:24:12.330 --> 07:24:15.208
S is they are there to solve transmission problems

07:24:15.900 --> 07:24:20.570
and facilitate markets and not be the solution to everybody

07:24:20.580 --> 07:24:26.178
all the time. So, would you agree that um as a path

07:24:26.189 --> 07:24:29.878
forward, we had no decisions on part of the commission

07:24:29.889 --> 07:24:33.740
at this meeting. But um it it would be prudent to ask

07:24:33.749 --> 07:24:37.049
staff to collaborate with her staff, our commission

07:24:37.059 --> 07:24:39.839
staff to collaborate with her staff in conjunction

07:24:39.848 --> 07:24:45.609
with the imm on a straw man uh uh budget and budgetary

07:24:45.619 --> 07:24:50.139
parameters associated with um the operationalization

07:24:50.150 --> 07:24:51.820
of this uh protocol.

07:24:55.178 --> 07:24:58.240
Well, I would say yes, I think that's fine. I mean

07:24:58.249 --> 07:25:01.199
the only thing that concerns me about

07:25:03.598 --> 07:25:07.589
the financial component is as I understand this, there's

07:25:07.598 --> 07:25:10.650
no board approval or anything, this is just you all

07:25:10.660 --> 07:25:13.389
deciding it and then whatever the bids come in, wherever

07:25:13.400 --> 07:25:16.749
you all threshold you, that's it. And without board

07:25:16.758 --> 07:25:20.320
approval, I think that would, that gives me more comfort

07:25:20.330 --> 07:25:23.790
that if there's something like that, at least whether

07:25:23.799 --> 07:25:29.949
it be codified or just a guidance, a request, a friendly

07:25:29.958 --> 07:25:30.779
request.

07:25:33.330 --> 07:25:36.400
Yes, I mean, because again, as I said earlier, I mean

07:25:36.410 --> 07:25:38.678
at the end of the day, the buck stops with us on

07:25:38.689 --> 07:25:40.109
protecting the consumer at the end of the day.

07:25:41.949 --> 07:25:43.529
Right? And so,

07:25:45.359 --> 07:25:48.779
you know, that as Commissioner Glotfelty just noted

07:25:49.230 --> 07:25:51.330
you know, the contracts won't get approved by the board

07:25:52.049 --> 07:25:55.019
And even if they did, we would still want to make sure

07:25:55.029 --> 07:25:59.839
that there's some kind of parameters that um you know

07:26:00.529 --> 07:26:03.990
address reliability, but also take the consumers into

07:26:03.999 --> 07:26:08.410
consideration as we look to ensure, you know, preparedness

07:26:08.419 --> 07:26:10.279
for, for the winter. And I think we got to strike a

07:26:10.290 --> 07:26:12.708
balance and the only way to strike a balance, I think

07:26:13.109 --> 07:26:16.859
that I can think of right now is this proposed budget

07:26:16.869 --> 07:26:20.878
analysis um with a collaborative approach to developing

07:26:20.889 --> 07:26:25.508
it. Um because it, the way I read the, the RP and

07:26:25.519 --> 07:26:27.339
the government documents of all the documents that

07:26:27.348 --> 07:26:29.839
are has provided us, I mean, I have a lot of questions

07:26:29.848 --> 07:26:32.240
I mean, I I haven't had the experience of dealing with

07:26:32.249 --> 07:26:34.678
like an RMR anywhere you know, other than reading about

07:26:34.689 --> 07:26:36.869
it, right? So I'm not really sure how all the different

07:26:36.878 --> 07:26:39.109
cost drivers work together, like the daily stand by

07:26:39.119 --> 07:26:41.958
payment incentive factor, the daily building factor

07:26:41.969 --> 07:26:44.660
and, and you know, fuel is like a big deal, right?

07:26:44.669 --> 07:26:47.839
I mean, especially based on FIP and fuel ladders that

07:26:47.848 --> 07:26:49.779
are provided by a resource entity. So there's just

07:26:49.790 --> 07:26:55.049
a lot there. And so I need to feel some comfort from

07:26:55.059 --> 07:26:57.900
a cost perspective that there are some parameters.

07:26:57.910 --> 07:27:00.249
And so that's the only option I can think of right

07:27:00.258 --> 07:27:05.980
now. And so long answer. Yes and then we can continue

07:27:05.990 --> 07:27:09.089
to think about this, this concept of how it fits within

07:27:09.098 --> 07:27:12.859
this, this bridging construct. I mean, I think that's

07:27:12.869 --> 07:27:15.540
going to require a little bit more thought on our part

07:27:15.820 --> 07:27:18.019
for the next couple of open meetings,

07:27:19.619 --> 07:27:22.598
you know, and it should be the the subject of consideration

07:27:22.878 --> 07:27:26.669
but at least there, look, there is a statutory reference

07:27:26.678 --> 07:27:32.150
to that um something that the market can, can grasp

07:27:32.160 --> 07:27:36.519
and see and it's tangible. Um It's something we can

07:27:36.529 --> 07:27:41.178
look to and how we adjudicate this process, this program

07:27:41.189 --> 07:27:45.330
moving forward because again, these costs will, will

07:27:45.339 --> 07:27:49.619
arrive at the doorstep of our consumers somehow. Well

07:27:49.628 --> 07:27:51.609
it's cost. And the other thing that I think is really

07:27:51.619 --> 07:27:54.910
important too is regulatory certainty. That is what

07:27:54.919 --> 07:27:57.508
we've been all working together towards trying to provide

07:27:57.519 --> 07:28:01.240
in this market for investment and expectations of cost

07:28:01.848 --> 07:28:05.389
And so the more regulatory certainty we can have in

07:28:05.400 --> 07:28:09.559
every tool and reform we're evaluating the better for

07:28:09.570 --> 07:28:10.098
everyone.

07:28:11.769 --> 07:28:16.508
Just one thing, I'm not there yet to say that a threemonth

07:28:17.070 --> 07:28:21.258
capacity discussion is a bridging solution. I didn't

07:28:21.269 --> 07:28:23.820
think you were and I wasn't asking that. I said, I

07:28:23.839 --> 07:28:26.598
think it's something we, we think about, you know,

07:28:26.609 --> 07:28:29.169
and, and continue to discuss, I mean, if this was something

07:28:29.178 --> 07:28:34.008
that ERCOT had proposed to do, you know, in every winter

07:28:34.019 --> 07:28:37.708
and every summer for the next five years, then yes

07:28:37.980 --> 07:28:40.889
But the only thing that's teed up in front of us is

07:28:40.900 --> 07:28:44.820
three months worth of work. And I don't, I don't see

07:28:44.830 --> 07:28:48.369
that as a bridging proposal yet. But yeah, and, and

07:28:48.378 --> 07:28:52.109
it was just my opinion that logic dictates we're going

07:28:52.119 --> 07:28:55.969
to need something moving forward because again, that

07:28:55.980 --> 07:28:58.580
generation will not be built overnight. And that was

07:28:58.589 --> 07:29:01.910
the premise. But did you have something you wanted

07:29:01.919 --> 07:29:05.449
to add? Just I want to clarify your ask from staff

07:29:05.589 --> 07:29:10.449
for the next open meeting. The ask is a, a strawman

07:29:10.458 --> 07:29:16.128
and I I frame it as a strawman budget proposal that

07:29:16.139 --> 07:29:19.330
you may work on with ERCOT staff including the IMM

07:29:19.820 --> 07:29:23.779
I consider that request consistent with what we did

07:29:23.790 --> 07:29:27.208
on not just formulation of ERRS but also firm fuel

07:29:27.219 --> 07:29:31.199
supply service. It sets a it should set a maximum bound

07:29:31.458 --> 07:29:37.199
of considered costs associated with the capacity RFP

07:29:37.639 --> 07:29:42.678
And not to say that ERCOT has to go all the way

07:29:42.689 --> 07:29:45.910
up to that cost similar to s or any other program that

07:29:45.919 --> 07:29:49.269
they manage that, that that can be at their discretion

07:29:49.919 --> 07:29:54.869
based on a reasonable standard, we can do kind of,

07:29:55.799 --> 07:29:57.848
so we can just kind of close the loop. Did you have

07:29:57.859 --> 07:30:00.749
anything you wanted to kind of add or any thoughts

07:30:00.758 --> 07:30:02.480
about that? We're happy to work with the commission

07:30:02.490 --> 07:30:06.878
staff and the imm on that guidance document, Tesla

07:30:06.889 --> 07:30:09.919
has a question. It's up to you if you want to recognize

07:30:09.939 --> 07:30:09.969
him.

07:30:13.678 --> 07:30:17.559
Um As I mentioned earlier, we're a retailer and a demand

07:30:17.570 --> 07:30:20.419
response aggregator. We're equally concerned about

07:30:20.428 --> 07:30:23.428
the cost and equally concerned about submitting an

07:30:23.439 --> 07:30:27.348
offer that may be viewed as egregious and ERCOT identified

07:30:27.359 --> 07:30:30.699
the hours of risk, the duration of deployment. So we've

07:30:30.708 --> 07:30:33.730
got the total number of hours. If you want to take

07:30:33.740 --> 07:30:36.859
the demand response budget off the table, stipulate

07:30:36.869 --> 07:30:39.519
a rate for demand response during declared events.

07:30:39.769 --> 07:30:42.919
So a fixed rate for residential demand response events

07:30:42.990 --> 07:30:46.458
would eliminate a capacity payment. No stand by payment

07:30:46.469 --> 07:30:50.040
just this is the rate residential enrolled demand response

07:30:50.049 --> 07:30:53.258
receives when they participate in a declared event

07:30:53.699 --> 07:30:56.389
so that we have a valuation that we can all agree upon

07:30:56.400 --> 07:30:59.480
We don't have to arrive at a budget for that segment

07:30:59.490 --> 07:31:03.889
of this exercise. And we don't have a perennial capacity

07:31:03.900 --> 07:31:06.900
market for demand response participation. Every single

07:31:06.910 --> 07:31:09.678
demand response provider, all of my associates stipulated

07:31:09.689 --> 07:31:13.040
that would help us recruit participation. So I appreciate

07:31:13.049 --> 07:31:16.730
your consideration. And is that as an alternative to

07:31:16.740 --> 07:31:19.269
the budget discussion or perhaps a compliment exclusive

07:31:19.279 --> 07:31:22.449
to residential demand response? Is that a dollar per

07:31:22.458 --> 07:31:25.799
kilowatt hour? That's how it's been implemented elsewhere

07:31:25.809 --> 07:31:29.269
Very successful. Yes, California, California. Soon

07:31:29.290 --> 07:31:32.279
to be Puerto Rico, Australia and other markets.

07:31:34.400 --> 07:31:37.339
Thank you for being recognized. I think that could

07:31:37.348 --> 07:31:42.359
fit under a budget concept. So anyway, I don't think

07:31:42.369 --> 07:31:44.208
we need, again, we're not making any decisions here

07:31:44.219 --> 07:31:46.689
We're trying to get our staff to work the problem,

07:31:46.699 --> 07:31:48.339
which I, I think they're willing to do.

07:31:52.910 --> 07:31:57.490
Ok, ma'am sure back to you. All right. Well, I think

07:31:57.499 --> 07:31:59.749
unless anybody else has any other questions, this wraps

07:31:59.758 --> 07:32:04.230
up. Um Section five. Um would y'all have any closing

07:32:04.240 --> 07:32:08.008
remarks um related to the work session and the day's

07:32:08.019 --> 07:32:12.080
activities? I I for one just want to thank everybody

07:32:12.189 --> 07:32:16.598
ERCOT stakeholders, um our own staff for hanging through

07:32:16.609 --> 07:32:20.400
this day. Um I think one of the objectives of this

07:32:20.410 --> 07:32:24.549
work session was to identify both the magnitude and

07:32:24.830 --> 07:32:30.139
degrees of protections and tools that we have developed

07:32:30.150 --> 07:32:33.059
and that we will have in place for this upcoming winter

07:32:33.070 --> 07:32:36.299
and how it all works together. I think we've demonstrated

07:32:36.309 --> 07:32:38.639
how many of these things will be working together.

07:32:38.650 --> 07:32:42.900
Plus the enhancement of potential additional tools

07:32:43.678 --> 07:32:49.910
tools that should open up our market to an expansive

07:32:49.919 --> 07:32:54.040
opportunity for participation from our residential

07:32:54.049 --> 07:32:58.878
and small commercial and industrial segments. And that's

07:32:58.889 --> 07:33:02.740
something that we haven't been able to uh to capture

07:33:02.749 --> 07:33:05.348
in the past. So this is an opportunity to beat the

07:33:05.359 --> 07:33:08.958
challenge of, of new load growth and a growing economy

07:33:09.419 --> 07:33:12.609
And um I, I hope, I hope the legislature, I hope the

07:33:12.619 --> 07:33:14.969
public sees it as such. So I just want to congratulate

07:33:14.980 --> 07:33:17.689
everybody and thank you for, for working so hard today

07:33:19.400 --> 07:33:22.499
Um I would say thank you to everybody who came and

07:33:22.508 --> 07:33:27.378
and who's online or listening, uh, staff. Um gosh,

07:33:27.389 --> 07:33:29.299
thanks for everybody sitting here for eight hours.

07:33:29.660 --> 07:33:34.169
Um I appreciate ERCOT. I don't know who's the man in

07:33:34.178 --> 07:33:36.139
the house over there, but I sure hope someone is, I

07:33:36.150 --> 07:33:37.119
appreciate you all being here.

07:33:38.910 --> 07:33:45.258
The thing that I'm appreciative of is sometimes on

07:33:45.269 --> 07:33:48.619
these hard issues. We have to have hard discussions

07:33:48.628 --> 07:33:55.749
And, you know, I think we've had a kind of my view

07:33:55.758 --> 07:33:59.650
is that this commission has kicked a lot to ERCOT for

07:33:59.660 --> 07:34:05.410
a long time. And then after the session, a few years

07:34:05.419 --> 07:34:08.070
ago, Senator Bill Two, Senator Three, we've kind of

07:34:08.080 --> 07:34:10.089
pulled some of that back and said, no, you can't do

07:34:10.098 --> 07:34:14.109
that. That's our realm. Um And we've created some of

07:34:14.119 --> 07:34:18.999
this challenge ourselves, but we are working through

07:34:19.008 --> 07:34:24.980
this as well to that end. I think that we have to

07:34:24.990 --> 07:34:28.160
count on ERCOT and their professionals to come up with

07:34:28.169 --> 07:34:30.008
ideas that may solve problems.

07:34:32.519 --> 07:34:36.049
I don't want them to surprise the industry or surprise

07:34:36.059 --> 07:34:37.919
us when they come up with these ideas. I want them

07:34:37.928 --> 07:34:40.730
to be collaborative so that we can solve these problems

07:34:40.740 --> 07:34:46.639
together. And I think that um you know, this, I think

07:34:46.650 --> 07:34:49.240
we'll get there on how that, how that working relationship

07:34:49.249 --> 07:34:54.258
works more and more. But um I think on transmission

07:34:54.410 --> 07:34:57.169
and you know, other planning things. I think if you

07:34:57.178 --> 07:35:01.559
all say we've got to do Xy and Z for transmission planning

07:35:01.570 --> 07:35:03.820
and Xy and Z for stability,

07:35:06.070 --> 07:35:08.609
extra megawatts and guess what it's going to happen

07:35:09.299 --> 07:35:14.269
So, being forceful, I think is valuable. Does that

07:35:14.279 --> 07:35:17.859
include 765 KV, Jimmy? No, I think that needs to come

07:35:17.869 --> 07:35:19.878
back to the commission. I think we need to look at

07:35:19.889 --> 07:35:21.708
that too. No, no, no, I'm not saying they make the

07:35:21.719 --> 07:35:23.570
decision in their own, right. I'm just saying they

07:35:23.580 --> 07:35:26.650
have to come but they're the ideas that the operators

07:35:26.660 --> 07:35:29.389
are the engineers and we have to work together. But

07:35:29.639 --> 07:35:34.230
if we don't know what these ideas are good work, it's

07:35:35.290 --> 07:35:38.330
I don't know, I'm just, I'm appreciative and uh you

07:35:38.339 --> 07:35:40.428
know, I think that we got a lot of work to do

07:35:40.660 --> 07:35:43.799
Yeah. Well, I, I too want to thank her and the stakeholders

07:35:43.809 --> 07:35:46.650
I mean, these are, this is just a tough chapter we're

07:35:46.660 --> 07:35:49.330
in right now. I mean, the last two years have just

07:35:49.339 --> 07:35:53.939
been just dominated by market reform, insuring reliability

07:35:53.949 --> 07:35:58.790
from one season to another. And yeah, so ERCOT is,

07:35:58.799 --> 07:36:01.859
are the, you know, market experts that are trying to

07:36:01.869 --> 07:36:04.869
come up with solutions and we're in tough positions

07:36:04.878 --> 07:36:07.949
too, right? It's commissioners here and trying to look

07:36:07.958 --> 07:36:10.059
out for, you know, the public interest and consumers

07:36:10.070 --> 07:36:12.589
But ultimately, we're all working towards the same

07:36:12.598 --> 07:36:18.089
goal, ensuring reliability, um you know, affordability

07:36:18.098 --> 07:36:20.208
I know it's not in your mission, but I, but you know

07:36:20.219 --> 07:36:23.878
II I know that y'all often point out where, you know

07:36:23.889 --> 07:36:26.469
there's cost savings. So, I mean, we're, we're trying

07:36:26.480 --> 07:36:30.499
to move all in the same direction puc ERCOT stakeholders

07:36:30.708 --> 07:36:33.650
It's just like Commissioner Gff. He said, you know

07:36:33.660 --> 07:36:36.639
these tough decisions are sometimes tough deliberations

07:36:36.650 --> 07:36:40.570
and we're working through all this in light of two

07:36:40.580 --> 07:36:43.980
sessions that have just been sort of modifying our

07:36:43.990 --> 07:36:47.249
relationships and, and everything with, with ERCOT

07:36:47.258 --> 07:36:50.848
with the industry. So, um really thank you to y'all

07:36:50.859 --> 07:36:53.549
and the stakeholders for being with us on a very long

07:36:53.559 --> 07:36:57.878
day and um appreciate all the involvement. Well, I

07:36:57.889 --> 07:37:01.549
also found this work session very insightful and informative

07:37:01.999 --> 07:37:05.309
and uh I personally think we have a tremendous team

07:37:05.320 --> 07:37:08.730
I wanted to give a special shout out to uh our market

07:37:08.740 --> 07:37:12.839
analysis staff um who worked so hard, kind of putting

07:37:12.848 --> 07:37:16.869
this together, doing a good job lining everybody up

07:37:17.128 --> 07:37:21.348
um and all the engagement from um from the public and

07:37:21.359 --> 07:37:24.178
from the stakeholders that participated, not just today

07:37:24.269 --> 07:37:27.330
but an ongoing basis. And uh I think, you know, as

07:37:27.339 --> 07:37:29.559
you look across Texas, you know, the one thing in my

07:37:29.570 --> 07:37:32.939
mind that kind of makes us uh kind of stand out maybe

07:37:32.949 --> 07:37:35.699
from some of the I OS is that, you know, I do

07:37:35.708 --> 07:37:38.490
do really believe that we care about one another and

07:37:38.499 --> 07:37:41.208
that we're looking out for one another and that, you

07:37:41.219 --> 07:37:44.040
know, we do work together collaboratively and as a

07:37:44.049 --> 07:37:48.928
team and always, you know, kind of thinking about reliability

07:37:48.939 --> 07:37:52.779
but also affordability and it is a tough challenge

07:37:52.790 --> 07:37:56.799
and, but um we have, we have the talent in Texas to

07:37:56.809 --> 07:38:01.290
do it. And um you know, we, we're, we're excellent

07:38:01.299 --> 07:38:04.549
at what we do. Uh We have kind of this, you know

07:38:04.559 --> 07:38:07.779
word is my bond attitude and we're not gonna stop until

07:38:07.790 --> 07:38:11.070
the job is done. And so I'm very encouraged that, you

07:38:11.080 --> 07:38:14.598
know, we took the time today. Um you know, ERCOT as

07:38:14.609 --> 07:38:17.830
you know, is, is doing some work with Texas A and M

07:38:17.848 --> 07:38:21.160
on a study about demand response uh as well as kind

07:38:21.169 --> 07:38:23.859
of bringing this to the forefront. And I think it's

07:38:23.869 --> 07:38:26.889
a discussion that uh again has, has been something

07:38:26.900 --> 07:38:28.928
that they've been wanting to have that we've been wanting

07:38:28.939 --> 07:38:31.570
to have and again, to kind of put that focus on the

07:38:31.839 --> 07:38:35.080
demand side of the equation. So, uh, I think we've

07:38:35.089 --> 07:38:37.559
we've made some, some great headway. I think there's

07:38:37.570 --> 07:38:41.428
been some great work that's been done and a little

07:38:41.439 --> 07:38:45.570
more to do, but we are going to finish the finish line

07:38:45.580 --> 07:38:48.330
We are gonna cross the finish line and in many ways

07:38:48.708 --> 07:38:52.320
it's a marathon, but it's also a race and we're gonna

07:38:52.330 --> 07:38:57.378
win. So, um, kind of moving forward and closing this

07:38:57.389 --> 07:39:00.419
out. Uh I don't think I have anything else for the

07:39:00.428 --> 07:39:04.650
remainder of the agenda. Uh, there is nothing for item

07:39:04.660 --> 07:39:09.119
17 which is closed session. There being no further

07:39:09.128 --> 07:39:11.529
business to come before the commission. This meeting

07:39:11.540 --> 07:39:14.628
of the Public Utility Commission of Texas is hereby

07:39:14.639 --> 07:39:17.348
adjourned at 504.