The PUC met on August 24 to take up a number of items including the ERCOT governance, electric market development, electric reliability, and the reliability standard for the ERCOT market. An archive of the hearing can be found here.
This report is intended to give you an overview and highlight the various topics taken up. It is not a verbatim transcript of the discussions but is based upon what was audible or understandable to the observer.
Item 1: Public Comment for matters not specifically posted on this agenda.
Stephanie Mace, AARP Texas
- On July 26 Texas Consumer Association submitted emergency petition project 55286
- Request PUC suspend 25.29i pertaining to disconnection of electric service during extreme weather
- Asks commission to impose a complete moratorium on all electric service disconnections of residents with past due bills until September 15
- With extreme heat a complete moratorium is a matter of public safety
- Urge the commission to direct the state transmission and distribution utilities and retell to report the number of electric accounts discounted for lack of payment
- McAdams – What happens if there is a heat wave October 1?
- We know potentially that hot weather could continue September 15 but we still believe the rule should be changed
- McAdams – So you ask us to resend our rule, place a broad-based moratorium through a date certain?
- The date could be changed and extended through September 15 if heat wave continues
- McAdams – If we are wrong and some sort of freak heat wave hits after the date certain consumers could be exposed, would they not?
- Have 100-degree weather; even if it goes down to 90 disconnections are still happening, topic could be discussed with more permanent solutions when weather is cooler
- Cobos – Is there a way that we can better communicate with you, so you can communicate with your customers?
- McAdams – I worry about winter, date certain conditions are problematic, I worry consumers will get harmed
Item 4: Docket No. 54153 – Application of Oak Bend Homeowners’ Water Supply Corporation for Authority to Change Rates. (Final Order)
- Delayed to the next meeting
Item 12: Docket No. 53601; SOAH Docket No. 473-22-2695 – Application of Oncor Electric Delivery Company LLC for Authority to Change Rates. (Order on Rehearing)
- Glotfelty – I want to extend time to act on the motion. Rate cases are not the best place to make policy decisions across the board. Use as pressure to get issues resolved. Need as much generation on the system as possible.
- McAdams – Would you hold up the finalization on rates of our largest utility?
- Glotfelty – Don’t want to, but it doesn’t really stop their business
- McAdams – It is regulatory lag
- Glotfelty – I can be happy doing this if I get the commitment of push for a rulemaking on generation and storage systems be worked on quickly.
- Glotfelty – Need rules to be defined and implemented state wide; if we can get a commission agreement to push for this I will agree to not extend time on this
- Cobos – I feel the parties haven’t raised any arguments we haven’t already heard and collaborated on, so I will not extend time
- Chair Jackson – I think there is a need to move forward
- Glotfelty – I am ok with not extending
- Motion to not extend time on the motions rehearing passes
Item 13: Docket No. 53602 – Application of Sam Houston Electric Cooperative, Inc. to Amend Its Certificate of Convenience and Necessity for a 138-kV Transmission Line in Polk and Tyler Counties. (Final Order)
- McAdams – How are you looking at this commissioner Cobos?
- Cobos – I would’ve consented this and approved the proposed order that adopts the reroute number 18
- McAdams – I agree
- Glotfelty – I agree
- Motion to approve the proposed order passes
Item 14: Docket No. 53625; SOAH Docket No. 473-22-00991 – Application of Southwestern Electric Power Company for Certificate of Convenience and Necessity Authorization and Related Relief for the Acquisition of Generation Facilities. (Order on Rehearing)
- McAdams – I would grant rehearing limited to the modifications to the order that I discussed in the memo, the findings of fact condition, the references to the Louisiana proceedings and I would move to grant re hearing to modify the order
- Cobos – What is recommendation on this motion for rehearing
- McAdams – I would not take that up
- Cobos – So denied?
- McAdams – Yes
- Motion to grant rehearing and modify consistent to McAdams’ memo passes
Item 16: Docket No. 53931; SOAH Docket No. 473-22-03499 – Application of Southwestern Electric Power Company for Authority to Reconcile Fuel Costs. (Final Order)
- McAdams – I have concerns about the settlement, but I don’t think we should take time and look at the PFD’s findings, I would ask to take this up at the next open meeting
- Cobos – I am ok will delaying it, but we can benefit from getting testimony on why they support it, also how the segregation of an oxbow lake in Sabine is an extra surcharge and explaining why carrying costs is the lynchpin or why is it sufficient
- McAdams – I agree
- Chair Jackson – So we all agree to delay action on this item until the meeting in September
- Motion to delay action passes
Item 17: Docket No. 54614 – Statement of Intent and Application of El Paso Electric Company for Approval of Texas Electric Vehicle-Ready Pilot Programs and Tariffs. (Discussion and possible action)
- Chair Jackson – SB 102 requires new statutory requirements that may impact this meeting. It would recommend El Paso Electric file a response in the next 30 days identifying which path it will pursue
- McAdams – I agree
- Glotfelty – I agree
- Motion to require El Paso Electric to file a response in the next 30 days passes
Item 19: Docket No. 55029 – Application of Wind Energy Transmission Texas, LLC for Interim Update of Wholesale Transmission Rates. (Order on Interim Appeal)
- Glotfelty – We should grant the appeal and overturn the ALJ and allow the cost to be examined by parties. WETT has not been in for a rate increase since 2015.
- McAdams – I do not believe ordering paragraph number 5 in the commission April 5 order limits parties to only at the face earning monitoring report; believe our rules are consistent
- Cobos – I would grant the appeal of order number 6, I want to make it clear that we are granting this appeal on the basis of the ordering paragraph 5 language
- McAdams – Bottom line they can go beyond the EMR?
- Cobos – Yes, based on the ordering paragraph language
- Motion to grant the appeal order number 6 consistent with discussion passes
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Item 24 Project No. 52301 – ERCOT Governance and Related Issues. (Discussion and possible action)
David Gordon, PUC Staff
- HB 1500 included new requirements related to ERCOT directives that will go into effect September 1. Staff has an interim process.
- New rules will be adopted but not before its effective date
- Beginning on September 1 ERCOT will not be directed by the commission orally
- Memo includes staff directive when new requirements will come into play
- Commission decide if directive causes new or increased costs
- Recommending a process where commissions staff files proposed directive no more than 9 days before meeting
- Only Commission staff or commission office has permission to file a proposed directive
- Staff is available to work with the commissioner
- This is a learning period on how to adopt the rule
- McAdams – On its face I do not disagree, but if commissioners have to file a memo at least 9 days before a meeting, I need information ASAP from ERCOT
- I don’t want to rush a decision of strategic importance
- McAdams – Any filing from ERCOT should be taken up not until the open meeting following the 30th day after the finding and staff strongly consider this in the upcoming rulemaking
- McAdams – I motion direct staff to adopt an interim process described in this memo and modified by potential discussion
- Cobos – There are two buckets: area of commission to ERCOT, filings we get from ERCOT (protocols) putting us on a deadline and filings we get from ERCOT, approved the board
- Sound like you’re saying when the board approves protocol, we have 30 days from the day ERCOT files
- McAdams – If we get anything from ERCOT that require PUC to act then I want us to consider that no earlier than 30 days before the next open meeting
- Cobos – What you focused on is protocols?
- McAdams – Correct
- McAdams – Any ERCOT recommendation, I want a deliberate window imposed
- Glotfelty – It might seem restrictive, but it’s not; everyone will adapt to this, I support this effort
- McAdams – This is policy of expectation management
- We don’t want staff making a decision that’s not thought out
- Cobos – It is important to set standards right now
- Glotfelty – This is a good draft and good addition
Item 35: Discussion and possible action on electric reliability; electric market development; power-to-choose website; ERCOT oversight; transmission planning, construction, and cost recovery; and electric reliability standards and organizations arising under federal law.
Pablo Vegas, ERCOT CEO
- Current operating conditions are extremely tight commissions today 08/24/23
- The demand is expected to be at near record levels and low wind performance during solar ramp down
- Usually, wind speeds increase during the evening
- Thermal dispatchable fleet is running normal forced outage levels
- If any dispatchable resources operated by other ISO systems could be delivered back to ERCOT that would be good
- McAdams – Fair to say the likelihood of an emergency energy alert condition is more likely?
- Yes
- Five market initiatives are:
- Making the floor changes to ORDC (Operating Reserve Demand Curve)
- The establishment of the reliability standard
- The development of a new ancillary service, DRRS, dispatchable reliability reserve service
- The development of PCM, Performance credit mechanism
- The development real time co-optimization engine for ERCOT
- Two memos filed one for reliability reserve and the second for the other four initiatives
- Within these memos is an initiative summary which capture the background of these initiatives
- My intention is give an update of these five initiatives
- Making Changes to the ORDC:
- Plan the develop a $10 floor when reserves are between 7000-6500 megawatts
- Plan would jump to $20 if it drops below 6500 megawatts
- Presenting binding documents and impact report in October
- See benefit before Winter
- Glotfelty – Do you think the ORDC is still needed if we move to a PCM and pay for capacity value?
- Vegas: Should look at the tools we have to incentivize the ERCOT grid, which is to reliant and efficient; is a little early to say that
- Glotfelty – Important to give an understanding to this market on what our ancillary services are and why we are using them and what they can bid into and what they can’t
- Ancillary services are not a capacity construct according to PUC rules
- Ancillary services are meant to ensure transmission service and power can flow reliably across the system
- McAdams – So they are operationally focused?
- Glotfelty – Correct, will need to work to figure out which ancillary services are necessary
- Flexibility is becoming a critical element so we have to be in a mindset that change is the norm
- McAdams – real time co optimization is supposed to harmonize our ancillary services and dispatch of those services negating the impact of ORDC. It will still have value but not what it is today
- The establishment of the reliability standard has three core components
- Development of reliability standard and the parameters that will make up the definition of it
- Identify what a reasonable loss of load in terms of frequency would be
- A definition of magnitude of Loss of load event is
- What the duration of a loss of load event could be & establishing limits for those and a probability exceedance criterion
- Two important studies must be done to help inform decision making around the reliability standard
- Value of Loss Load (VOLL)
- Serving customers across different classes to determine what the value of energy would be at a point of time when it would not be available in order to assess how much should be invested to create a reliability standard
- Cost of New Entry (CONE)
- Cost of resource mix is informed by CONE
- Today we have proposed 48 scenarios that have variations of loss of load duration and magnitude along with different resource mixes
- Our hope is to have these outputs by the open meeting on September 14
- We are initiating an RFP for the CONE study
- We would like to have the iterations worked through the next quarter
- Cobos – CONE study is important for two reasons, parameters for the market everyone looks at to evaluate the cost of entry and HB 1500 in our assessment of the PCM
- Cobos – page 3 of the filing “Under scope these market initiatives will implement a mandatory reliability standard and determine updated input value for VOLL and CONE”
- Cobos – Suggesting we mandate the reliability standard?
- Its mandatory we develop it because of legislation; I would issue a mandate
- Cobos – I am worried how we are going to mandate the reliability standard
- It’s a complicated market, we would leverage all the tools we have to achieve that
- The word does not supersede any of the authority the commission has it just intended to establish that it’s a legislative requirement to have one and once established using all measures to achieve it
- Chair Jackson – I believe this is a great starting point for the reliability standard
- McAdams – In terms of the contractor who will manage the VOLL survey, when will that be publicly available?
- I expect it to be in the coming weeks
- The development of a new ancillary service, DRRS, dispatchable reliability reserve service
- New ancillary service that was mandated in HB 1500, it has operating requirements that the resources that deliver that whether load or supply have to be able to come online in two hours and have to be able to run and operate for a minimum of four hours
- ERCOT needs to reduce RUC by the equivalent amount of DRRS acquired
- We evaluated 3 different approaches to achieve an efficient timeline: traditional standalone ancillary service, replacing non spent product, creating sub type of non-spin product
- We found it more reliable to preserve the value of the non-spin product and add a sub type that would allow product between 30 minutes and 2 hours to come online to meet the requirement DRRS and deliver on the four-delivery strategy
- Safer to preserve the nonspin product. Then deliver on the 4-hour deliverability requirement.
- McAdams – Will those two categories settle the same?
- Yes, it would be a sub type of the already being used non spent. Can segment resources out.
- McAdams – One common price for the ancillary?
- Yes; one single clearing price
- McAdams – So you’re going to pay a peaker the same as something that ramps really slow
- Potentially, it’s not optimal; optimally would develop a standalone ancillary service
- McAdams – Has staff made the final decision on this?
- Still working through it, but that is the direction we are moving toward
- DRRS timing will file NPRR between September and October; present to the board in December and then the Commission in January
- Development of the actual product between January and November with goal of launching in December
- Chair Jackson – Will have a 6-month evaluation period?
- Yes; would like to have a schedule with the commission to evaluate impacts
- Glotfelty – Important to have a third-party reviewer for that
- Glotfelty – Procure ancillary services once a year; concerned as the system changes the way we do that doesn’t change; need to move to something more specific to that season/month/week/day
- Point is well taken; gets back to the flexibility conversation
- McAdams – Will have more discussions on this; concerned about paying a peaker the same as a combined cycle to ramp into ancillary
- McAdams – ECRS would not be better for the 30-minute?
- Kenan Ă–gelman, ERCOT – Not a unit specific ability to dispatch and non-spin does
- Glotfelty – Is that why we see the combinations
- Kenan Ă–gelman, ERCOT – Has been in some instances, but have been unique cases
- Glotfelty – What about RRS?
- Kenan Ă–gelman, ERCOT – RRS has specific requirements concerning shocks to the grid; sits in NERC requirements; generally RRS comes in after below 3k MW of reserves and required to respond to contingency
- Cobos – Peaker participating in non-spin and ECRS is based on the technology of that peaker?
- Kenan Ă–gelman, ERCOT – Combustion generally have quick combustion with quick start mode, but operators have to make decisions on how to optimize that service; fill buckets relatively to what is needed
- Chair Jackson – Sounds like the path forward to keep flexibility and then evaluate from time to time
- Commission approved PCM framework in January and HB 1500 put parameters around how it would operate
- Working on a framing document to develop key definitions and decisions that will need to be made early
- For example, would create a scarcity hours definition, how many, what periodicity used to evaluate those scarcity hours, non-performance costs, etc.
- Expect to develop this September/October and commission feedback in October; would be getting input from the market at the same time
- Would develop an initial proposal on how the PCM would work
- Next will have workshops with the PUC in the first and second quarters of next year to design the PCM
- Once design is set, will do a cost study with the IMM mandated by the legislation; expect this during the third/fourth quarter; goal of the cost study to be done by the end of next year
- Goal is to have design/cost evaluation/recommendation on moving forward to be together by the time the next legislature is in session in 2025
- Would then develop protocols/technology in 2025 and then delivery in 2026
- Members ask a number of timeline questions
- Glotfelty – ERCOT and IMM charged with doing a cost study; independently? Hoping they are separate
- Not clear on how it technically needs to be done; want the cost study to be together
- Will work closely with the IMM and present one document with some differences but with one recommendation on how to move forward
- McAdams – Let’s work on that
- Cobos – After framing document, what happens?
- Would tell you to move forward to develop the actual proposal
- McAdams – Will be one big discussion or multiple?
- Will be multiple; expect even a couple iterations of that first document
- Chair Jackson – Idea is there will be multiple decisions along the way
- Glotfelty – Not seeing any TAC involvement planned, hope they and other subcommittees are involved in the process
- They will be
- Cobos – Somewhere along the process the CONE study will be occurring?
- Correct
- Cobos – Reiterates timeline; want to make sure we comply with HB 1500 on the cost assessment
- McAdams – 3 minutes for real-time optimization; is current controversy with the not commission approved NPRR 1186; would advise to strike linkage with this NPRR and ultimate implementation of real time co-optimization
- Is a standalone solution currently
- McAdams – Want language to show a more neutral approach
- Glotfelty – 1186 is a big challenge; batteries do not look like a coal plant on our system; if batteries bid into ancillary services for an hour, why should they have an hour left over at the end of the charge?
- Glotfelty – In accordance with your rules, it is increasing the pricing; do not believe we are going to finalize this in its current form
- Underlying driver is to ensure operational reliability are also drivers in place to ensure economic opportunity; my priority is reliability
- Lean on my operators to make these hard decisions
- Glotfelty – Need to have an open conversation with those operators; believe the market could solve this problem; if we do not know what operators are doing, that is an issue
- Happy to have more open conversation; need to put something in place or else we will have nothing because of the limits in the grid management systems before the lockout and RTC development
- RTC solution is potentially different than the 1186 solution
- Glotfelty – Getting something in place is secondary to getting something right
- McAdams – Do not want to disincentivize long-term batteries while incentivizing short-duration batteries
- Expect to have RTC state of charge at the board/commission by the end of this year; expected delivery in 2026
- ERCOT filed a market notice to the Barney Davis Gas Facility in Corpus Christi; they submitted a notice to cease operations in November 2023
- Local reliability analysis does not show local reliability issues if this unit were to retire
- Looking at needed capacity for this coming winter as there are a number of retirements; will look to see if additional capacity contracts are needed
- Cobos – Will be looking at unit performance and outage history especially for winter?
- Yes
- Cobos – Will ERCOT evaluate a demand-side solution?
- Yes, required to evaluate any capacity options on supply/demand side
- Cobos – Anticipate bringing something forward, if needed, to our October meeting?
- Correct
- McAdams – Will be an expensive decision
- Chair Jackson – Cost analysis would be required?
- Correct
- Notes ERCOT issued a formal conservation notice on August 24
Item 42: Closed Session
- The commission met in closed session
- After returning, the commission approved the mediated settlement agreement Dialtone LLP v. PUC and authorize Attorney General to enter into agreement on behalf of the PUC
- The commission appointed Shelah Cisneros as Commission Council of OPDM
Item 27: Project No. 53911 – Aggregate Distributed Energy Resource (ADER) ERCOT Pilot Project. (Discussion and possible action)
- Chair Jackson – McAdams and Glotfelty filed a joint memo
- McAdams – Invited the ADER leadership to be here, yesterday announced the first two ADERs have been approved to participate in ERCOT market
- McAdams – Two ADERs are bundles Tesla electric residential customers and are separated in the North load zone and Oncor’s territory, and in the Houston load zone and CenterPoint’s territory
- Almost 1 year since ADER taskforce was formed last August
- ADER leadership will be speaking on milestones, hurdles, and advancements
- Glotfelty – Echo your thoughts, glad we did this together and have such an able team; should all be excited about this
Jason Ryan, CenterPoint Energy
- Important to pause to celebrate good news, TX is a world leader in virtual powerplant implementation
- Give a lot of credit to PUC in leading in this space; changes how customers are using the distribution grid
- In August of last year had no answer on how to do this and no clear path forward, got that on August 12 with PUC memo
- Charter that governed the taskforce work set out that it needed to be done transparently
- Also told us in the charter to bring disagreements to the attention of the PUC; group of 20 people never needed to make such a filing & reached consensus
- Wanted to have ERCOT approval of pilot by October, 30-45 days between charter filing and getting started
- Governing doc was approved on time, then let marketplace work on implementation while task force was working on business processes and legislative clarifications last session; Chair Hunter carried a bill that passed these clarifications
- There was a clarification in the memo filed this week on what is needed next; agree with press release yesterday that this can be a model for other PUC priorities
- Implementing resilience plan legislation is an important next step, important to have greater resilience on distro grid
Arushi Sharma Frank, Tesla
- Thanks PUC & congratulates them for launching market pilot with Tesla aggregations of Oncor and CenterPoint customers
- Tesla customers will be here talking about their experiences
- Most important piece of ADER reliability is that every customer arrives to the pilot themselves; weight off the cost to state to have more customers to spend their own money to participate
- Every customer is providing reliability services and taking off socialized value of reliability standard
- Need to be able to see a resource in the system, needs to be understood & needs to be part of wholesale price generation
- Other options are passive demand control
- Close to operationalizing 6 ADERs in the state
- Sharing information between 3 entities that haven’t before about scope, scale, and system capacity for DER; pilot has enabled granular info exchange & taskforce can pass info to interested parties to develop reliability standard
- All of this happening in 9 months is progress that is taking others years to implement
- Info collected will be incredibly important to the national labs & TX will be helping them figure out how to monetize DERs
- In the beginning we were focused on getting quantity into the pilot, but haven’t spent as much time on quality; started as a crowd-sourced investment, but needs to become investment grade & investments need to be driven from many sources
- Need to fix some quality control issues, incl. caps on entities like Tesla, cannot innovate with the current caps
- Standards in the governing doc work well if taskforce was validating info from large resources, but don’t make sense for the small and precise resources in the DER; small deviations look much larger than they are under the current standard
- Every ADER needs to be registered as a controllable load resource to be modeled in the system, so need to be registered by TDSP and load zone; two challenges there 1) breaking up large load zones runs into fixed cost issues and interferes with break even point 2) real-time operation of a controllable load resource
- Aggregated small batteries are great front-of-the-meter ESR, so there are issues with classifying these in the system based on this behavior
- Next step is getting these issues down, technical aspects of how these resources operate; QSEs need to learn this & want to socialize this through ERCOT
- Looking nationally, load growth was anemic 20 years ago and DERs weren’t thought of; this is changing quickly and TX is ahead
- Customers will keep adopting devices and will do this under a variety of funding models
- Standard is one piece of the puzzle, other piece is making sure programs exist allowing customers to optimize the value of storage; needs to be model to get customers to the right level of tech and this can be operationalized via an ADER
- Recommends PUC add an additional goal to explore storage and DER tariffs that are more sensible models for LSEs managing load on the system & having value monetize itself in the wholesale market
Kenan Ă–gelman, ERCOT
- To be able to have aggregation follow base points so it can provide non-spin is an accomplishment to celebrate, hasn’t been done anywhere else & this is not easy
- Biggest lesson learned is in validating data, applied 24-hour standard and were able to capture things failing on a single watt level; moving away from this was key to getting people qualified & will require change in the governing document and have started drafting this
- McAdams – Not that we’ve operationalized this and cleared the hurdle of the governing doc, how does this program evolve? Learning more day-to-day, now have ECRS that is live, aggregated load response program and protocol has been repurposed to house demand response and virtual powerplants, etc.
- Ogelman – Definitely need to start talking about what is feasible around ECRS, but just now accumulating data around how this performing
- Area we push back on is if we’re achieving reliability objectives and if data supports this
- Have one entity that has qualified, would like to see many more; not easy to move the data around like Tesla has achieved, want to make sure others understand how this works, what is good practice, etc.
- Glotfelty – Appreciative that ERCOT came to the table and said yes to this in the beginning, glad you’ve seen the value
- McAdams – Ask for enhancements to deliverables; need taskforce to start collecting reasons and incentivize competition & broad participation; ERCOT should try to outline how the program could evolve over the next quarter & try to identify other things ADERs could participate in
- McAdams – Have heard comment that concentration of these devices are not at scale and could cause noticeable impact on transmission; would like taskforce to work on what info we can collect from the pilot to support the ADER program, what the critical mass threshold is that PUC can work with
- Would like the taskforce membership to stay the same over the next year, valuable to keep current composition if possible to better refine lessons and begin talking about how to scale
- Would like taskforce to update membership where delegated and submit those under this project
Item 31. Project No. 55323 – Review of Renewable Portfolio Standard. (Discussion and possible action)
- Chair Jackson – PUC staff filed a memo
Iliana De La Fuente, PUC Staff
- Talking about Renewable Standard Portfolio & it’s repeal
- Statute required PUC to create a REC & PUC created mandatory RPS
- HB 1500 restricts REC to solar-only star4ting Sept. 1, 2023 and repeals the program completely Sept. 1, 2025
- Mandatory standard lacks statutory support after Sept. 1, staff is recommending following 5 steps outlined in memo
- Chair Jackson – So to reiterate, staff is recommending directing ERCOT to suspend allocating RPS obligations to retail entities effective August 31, 2023, establish a modified 2023 compliance period, and maintain an accreditation & banking system to awarding RECs; agree with memo and staff recommendations
- Glotfelty – On maintaining an accreditation & banking system, legislature was thinking of renewables, but as we move into green hydrogen and things like that it is critically important that there is a REC associated with that component; this is a certification to prove it is green hydrogen
- Motion to approve staff recommendations passes
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Items 32 & 33 were taken up together
Item 32. Project No. 37344 – Information Related to the Entergy Regional State Committee. (Discussion and possible action)
Item 33. Project No. 41211 – Information Related to the Organization of MISO States. (Discussion and possible action)
- Chair Jackson – Cobos filed a memo
- Cobos – Update on some activity through ERSC and ORS; MISO is expected to file a tariff revision at FERC to implement reliability-based demand curve proposal, essentially a downward sloping curve with opt-out mechanism
- Cobos – ERSC adopted a resolution that focuses on the opt-out mechanism that MISO laid out, MISO’s current proposal requires an LSE to make a showing of additional capacity beyond current resource adequacy requirement
- Could result in LSE’s having a larger resource adequacy requirement
- Looking at possibly making this less attractive by getting people to put capacity into the PRA & also from a cost perspective because opting out from PRA carries extra requirement subject to penalties
- ERSC filed a resolution that MISO adopt an opt-out provision consistent with Entergy companies’ AFRAP proposal
- Based on PUC review, Entergy’s proposal allows LSE to sell a set amount of load, provides flexibility on how much they are required to put into PRA
- ERSC laid out its position on why it wanted MISO to consider AFRAP, has been sent to MISO leadership
- OMS submitted a letter to MISO supporting their demand curve proposal and their proposed opt-out mechanism
- We’re trying to assert our position so MISO can take that into consideration & examine next steps if MISO files tariffs with FERC
- McAdams & I are working to ensure ratepayer perspective is protected in these other markets
- MISO is facing the same resource adequacy problems as other ISOs around the country; they’ve been looking at changes to the PRA, but we’re also looking at underneath the PRA to the opt-out mechanism that could result in cost to ratepayers
- McAdams – Does Dr. Patton have a view on the fairness of this?
- Cobos – Understand he supports a downward sloping curve & he would like to see all capacity from an economic standpoint; has been advocating for a downward sloping curve for quite some time
- Everyone looked at modeling and how to better set up the PRA option; may be good concept, but the opt-out and having all capacity participate is problematic
- McAdams – All of the capacity isn’t actually deliverable, so this is just an arithmetic exercise for workbook certification meaning nothing in terms of capability
- Cobos – Different states are in different positions, downward curve if you’re long could be beneficial compared to if you’re short and subject to penalties; every state is advocating for its position
- Entergy has an all-dispatchable portfolio that ratepayers will be paying for
- Chair Jackson – Appreciate you looking out for TX and ratepayers in TX
Item 35. Discussion and possible action on electric reliability; electric market development; power-to-choose website; ERCOT oversight; transmission planning, construction, and cost recovery; and electric reliability standards and organizations arising under federal law.
- Chair Jackson – Glotfelty will be leading a new advanced nuclear reactor workgroup; Advanced Nuclear State Collaborative, designed to enhance understanding of nuclear generation
- Glotfelty – Filed memo requesting new project number to be the catchall for the new workgroup, will have much more info coming in the September meeting
- McAdams – Will this follow the paradigm of the ADER taskforce? Governing doc, set number of members, etc.?
- Glotfelty – Working on that right now
- Chair Jackson – People across the state are asking about nuclear generation
- Glotfelty – Other PUC members will be part of this as well through the docket number
Item 39. Discussion and possible action regarding agency review by Sunset Advisory Commission, operating budget, strategic plan, appropriations request, project assignments, correspondence, staff reports, agency administrative issues, agency organization, fiscal matters, and personnel policy.Â
- PUC Staff – Modifications around process for public comment, HB 1500 requires public comment as an open meeting item; developed process that is in alignment with bill and conforms to intent of the legislature
- Regarding public comment on items not on the agenda, will be taken up with Item 1, comment for items on the consent agenda will be taken up at the start of the meeting, for comment on items not on the consent agenda counsel will lay out the item and then call public comment on items individually
- Conforms to intent & letter of the law; very close to what TCEQ does
- Will start at the next open meeting in September, working on a guidance doc
- Chair Jackson – Format for public comment will be different at the next meeting