WEBVTT 00:00:08.460 --> 00:00:10.210 All right. 00:00:10.210 --> 00:00:12.290 We will now reconvene this meeting 00:00:12.290 --> 00:00:14.393 of the Public Utility Commission of Texas. 00:00:19.138 --> 00:00:20.930 We are gonna bring up again, 00:00:20.930 --> 00:00:25.930 docket 51023 for one more public speaker 00:00:27.200 --> 00:00:31.233 to present oral testimony, three minutes, 00:00:32.070 --> 00:00:33.050 as with all the others. 00:00:33.050 --> 00:00:34.880 Three minutes, please, sir. 00:00:34.880 --> 00:00:38.649 Please state your name and who you're with for the record. 00:00:38.649 --> 00:00:39.482 All right. 00:00:39.482 --> 00:00:40.920 My name is Raul Figueroa. 00:00:40.920 --> 00:00:44.380 Last name is spelled F-I-G-U-E-R-O-A 00:00:44.380 --> 00:00:49.130 and I live at 26670 Karsch Road in High Country Ranch 00:00:49.130 --> 00:00:51.270 and I'm habitable structure umber 16 00:00:51.270 --> 00:00:52.823 on the CPS inventory map. 00:00:54.510 --> 00:00:56.267 I oppose recommended Route C2 00:00:56.267 --> 00:00:58.660 and the proposal for a decision. 00:00:58.660 --> 00:01:01.110 The PFD is flawed in my opinion, 00:01:01.110 --> 00:01:04.270 because it has errors regarding my home 00:01:04.270 --> 00:01:06.580 and the High Country Ranch neighborhood. 00:01:06.580 --> 00:01:09.100 As I stated in my exception, AOJ 00:01:09.100 --> 00:01:12.650 described me as a landowner, close to High Country Ranch. 00:01:12.650 --> 00:01:15.700 This is incorrect as I am a home and landowner 00:01:15.700 --> 00:01:18.350 inside High Country Ranch. 00:01:18.350 --> 00:01:21.390 The AOJ's also a state in the PFD that Route C2 00:01:21.390 --> 00:01:24.800 does not cross a neighborhood. 00:01:24.800 --> 00:01:27.610 This is another incorrect statement as Route C2 00:01:27.610 --> 00:01:30.810 segment 46B runs across the High Country Ranch 00:01:30.810 --> 00:01:32.080 neighborhood. 00:01:32.080 --> 00:01:34.250 Route C2 segment 46B, 00:01:34.250 --> 00:01:37.533 which surrounds my home and property on three sides. 00:01:38.410 --> 00:01:41.260 When my wife and I purchased our home in 2014, 00:01:41.260 --> 00:01:43.390 one of the deciding factor was whether 00:01:43.390 --> 00:01:46.000 we could spend the rest of our lives in it. 00:01:46.000 --> 00:01:47.500 And the answer was a definite yes. 00:01:47.500 --> 00:01:49.350 We consider it our forever home. 00:01:49.350 --> 00:01:51.653 It has a 20 mile view to the west. 00:01:53.280 --> 00:01:54.890 It has the 20 mile view to the east 00:01:54.890 --> 00:01:56.993 and a beautiful view to the west. 00:01:57.910 --> 00:02:00.070 I asked the Commission to imagine stepping out 00:02:00.070 --> 00:02:02.460 of your home and seeing a transmission line segment 00:02:02.460 --> 00:02:05.250 from three sides of it ranging from 162 feet 00:02:05.250 --> 00:02:07.320 to approximately 300 feet. 00:02:07.320 --> 00:02:09.750 This is exactly what my family and I would experience 00:02:09.750 --> 00:02:13.347 every single day should recommend Route C2 00:02:13.347 --> 00:02:15.010 and the PFD get approved. 00:02:15.010 --> 00:02:17.240 My wife's stepdaughter and I will not have 00:02:17.240 --> 00:02:19.240 one single enjoyable area around our home 00:02:19.240 --> 00:02:21.670 without staring directly at a transmission line. 00:02:21.670 --> 00:02:23.730 The only side of our home that will not face 00:02:23.730 --> 00:02:24.963 a transmission line, 00:02:27.130 --> 00:02:29.490 sits a garage and a fence line that separates 00:02:29.490 --> 00:02:31.393 my property and my neighbors. 00:02:32.390 --> 00:02:35.210 My wife suffers from a condition called bipolar II, 00:02:35.210 --> 00:02:37.830 for which she must take medication on daily basis. 00:02:37.830 --> 00:02:40.510 She keeps this health issue private, 00:02:40.510 --> 00:02:44.900 but authorized me to go ahead and mention it 00:02:44.900 --> 00:02:48.093 in order to emphasize the importance of a serene view, 00:02:49.750 --> 00:02:53.500 of a stress-free view and environment. 00:02:53.500 --> 00:02:54.510 You have one minute left, sir. 00:02:54.510 --> 00:02:55.343 Okay. 00:02:56.790 --> 00:02:59.900 The biggest symptom of this condition is depression, 00:02:59.900 --> 00:03:01.860 which she must take medication for, 00:03:01.860 --> 00:03:04.570 but also the beautiful view helps her as well. 00:03:04.570 --> 00:03:06.683 That's a natural remedy for it. 00:03:10.570 --> 00:03:12.900 Furthermore, the transmission lines around my home 00:03:12.900 --> 00:03:15.000 on three sides, there's a high probability 00:03:15.000 --> 00:03:16.300 that the transmission line 00:03:17.248 --> 00:03:19.130 that it will cost interference with my cell phone 00:03:19.130 --> 00:03:21.080 reception and Wi-Fi. 00:03:21.080 --> 00:03:24.500 The CPS witness could not guarantee or make assurances 00:03:24.500 --> 00:03:27.550 that my cell phone reception would not be interrupted. 00:03:27.550 --> 00:03:30.290 I work from home on a full-time basis 00:03:31.365 --> 00:03:32.420 for an out-of-state employer that provides 00:03:32.420 --> 00:03:35.000 software solutions to department defense contractors. 00:03:35.000 --> 00:03:36.630 And it's vital that my cell phone service 00:03:36.630 --> 00:03:37.973 and internet be reliable. 00:03:40.330 --> 00:03:42.320 I am baffled to the fact that the administrative judges 00:03:42.320 --> 00:03:45.760 did not select Route P instead of Route C2. 00:03:45.760 --> 00:03:48.860 I urge the Commission to please consider Route P 00:03:48.860 --> 00:03:53.543 or any Northern route that does not include segment 46B. 00:03:54.838 --> 00:03:57.193 And I'm also not opposed to Route Y. 00:03:58.330 --> 00:03:59.840 Thank you for being here 00:03:59.840 --> 00:04:01.730 and thank you for accommodating the delay. 00:04:01.730 --> 00:04:02.700 Sorry, we didn't get you in on that. 00:04:02.700 --> 00:04:03.533 No, not a problem. 00:04:03.533 --> 00:04:04.400 Original sign-up. 00:04:04.400 --> 00:04:05.650 Thank you again. 00:04:05.650 --> 00:04:06.483 I appreciate it. 00:04:08.920 --> 00:04:10.279 All right. 00:04:10.279 --> 00:04:14.650 That concludes business on docket 51023 for the day. 00:04:14.650 --> 00:04:16.823 We'll table that for a future open meeting. 00:04:18.840 --> 00:04:23.072 Next item I believable will be docket 53116. 00:04:23.072 --> 00:04:23.905 You may state your name. 00:04:23.905 --> 00:04:24.845 Yes, sir. 00:04:24.845 --> 00:04:27.300 Item 14 is docket 52116. 00:04:27.300 --> 00:04:32.300 It is an agreed NOV between SWEPCO and Commission staff 00:04:33.720 --> 00:04:36.010 regarding the reliability standards. 00:04:36.010 --> 00:04:39.447 A revised preliminary order incorporating, 00:04:39.447 --> 00:04:41.550 I mean, proposed order incorporating corrections 00:04:41.550 --> 00:04:44.063 was filed on September the 14th. 00:04:45.590 --> 00:04:46.423 All right. 00:04:47.890 --> 00:04:50.670 Open up for discussion if anybody's got thoughts 00:04:50.670 --> 00:04:52.403 or comments or questions. 00:04:53.827 --> 00:04:55.570 Can I make a general statement? 00:04:55.570 --> 00:04:57.230 Absolutely. 00:04:57.230 --> 00:04:59.831 Not that I need your permission, but thank you. 00:04:59.831 --> 00:05:02.081 (laughing) 00:05:03.150 --> 00:05:06.780 We've seen a lot of these settlements 00:05:06.780 --> 00:05:11.780 come across the dais here since I've been on the Commission. 00:05:11.950 --> 00:05:14.240 I don't know if that's common or not, 00:05:14.240 --> 00:05:16.960 but they all deal with (indistinct) and safety 00:05:16.960 --> 00:05:18.510 and they're all dealing with... 00:05:18.510 --> 00:05:20.700 So that's the frequency and the duration 00:05:20.700 --> 00:05:22.750 of outages and how they affect consumers. 00:05:24.030 --> 00:05:28.317 I had a discussion with SWEPCO last week 00:05:29.900 --> 00:05:32.520 about a recent outage, 00:05:32.520 --> 00:05:35.610 where they had a 20 foot tree growing in the right of way. 00:05:35.610 --> 00:05:40.203 And 6,000 to 7,000 residents lost power 00:05:41.560 --> 00:05:43.240 for a certain amount of time. 00:05:43.240 --> 00:05:45.280 They admitted that they made a mistake 00:05:45.280 --> 00:05:46.240 and how it happened. 00:05:46.240 --> 00:05:47.090 And I understand it. 00:05:47.090 --> 00:05:50.920 But again, what I go back to is vegetation management 00:05:50.920 --> 00:05:52.703 is so key in these issues. 00:05:54.260 --> 00:05:55.810 A 20 foot right of away, 00:05:55.810 --> 00:05:59.763 they claim that they use insecticide or herbicide 00:06:03.270 --> 00:06:04.103 in the right of way. 00:06:04.103 --> 00:06:06.963 But the plan was to cut the tree down next year. 00:06:08.822 --> 00:06:12.091 Well, we've gotta do better than that is what I'm saying. 00:06:12.091 --> 00:06:14.630 We can't let 20 foot trees go in our rights of away. 00:06:14.630 --> 00:06:17.300 It doesn't matter when we plan, 00:06:17.300 --> 00:06:18.670 we gotta use technology. 00:06:18.670 --> 00:06:20.820 We gotta find ways to make sure 00:06:20.820 --> 00:06:23.963 that these rights of ways that we've granted, 00:06:26.015 --> 00:06:29.520 that these utilities manage for the good of consumers 00:06:29.520 --> 00:06:32.340 are kept clean and that, you know, 00:06:32.340 --> 00:06:34.430 trees that are growing like that, 00:06:34.430 --> 00:06:36.930 especially in wet weather years or the year after. 00:06:37.850 --> 00:06:39.520 These aren't hard issues to resolve. 00:06:39.520 --> 00:06:41.050 They're time-consuming, they're costly. 00:06:41.050 --> 00:06:45.380 But in my opinion, we have to see better on this space. 00:06:45.380 --> 00:06:48.060 Especially if you know the problem's there. 00:06:48.060 --> 00:06:48.893 That's right. 00:06:50.306 --> 00:06:52.556 This year, not next year. 00:06:55.723 --> 00:06:57.373 I agree with everything you said. 00:06:58.264 --> 00:07:01.960 I know this is an issue you've also (indistinct) 00:07:01.960 --> 00:07:05.530 and I appreciate that focus and support the direction 00:07:05.530 --> 00:07:07.000 both of y'all are taking. 00:07:07.000 --> 00:07:10.890 It's often overlooked, 00:07:10.890 --> 00:07:14.633 but absolutely critical part of day-to-day reliability. 00:07:15.620 --> 00:07:17.980 Any other thoughts or comments? 00:07:17.980 --> 00:07:19.180 No. 00:07:19.180 --> 00:07:23.540 I was comfortable with the revised proposed order 00:07:23.540 --> 00:07:28.540 and would make a motion to approve the revised order. 00:07:34.440 --> 00:07:35.290 So moved. 00:07:35.290 --> 00:07:36.530 Second. 00:07:36.530 --> 00:07:37.646 All in favor, say aye. 00:07:37.646 --> 00:07:38.479 [Commissioners together] Aye. 00:07:38.479 --> 00:07:39.313 Motion passes. 00:07:41.390 --> 00:07:42.990 Next item, please. 00:07:42.990 --> 00:07:44.400 Number 18, I believe. 00:07:44.400 --> 00:07:45.629 Yes, sir. 00:07:45.629 --> 00:07:47.420 Item 18 is docket 52282. 00:07:47.420 --> 00:07:49.510 It's a complainant BHC property management 00:07:49.510 --> 00:07:51.233 that gets NG Resources. 00:07:52.400 --> 00:07:54.630 Drop preliminary orders filed on October 19th. 00:07:54.630 --> 00:07:57.143 Commissioner McAdams has a memo in this matter. 00:07:57.980 --> 00:07:59.580 Would you like to lay out your memo? 00:07:59.580 --> 00:08:02.840 Well, I was excited to see this case 00:08:04.110 --> 00:08:06.380 show up on the agenda. 00:08:06.380 --> 00:08:10.790 And it was because this is sort of our first opportunity 00:08:10.790 --> 00:08:13.680 to take a bite out of an apple or an issue 00:08:13.680 --> 00:08:16.201 that we have been talking about 00:08:16.201 --> 00:08:18.280 since I came into the Commission and you Mr. Chairman, 00:08:18.280 --> 00:08:19.483 and so on. 00:08:25.977 --> 00:08:26.810 Form contracts, mean form contracts. 00:08:26.810 --> 00:08:29.290 And we had this whole conversation 00:08:29.290 --> 00:08:31.520 after Winter Storm Uri 00:08:31.520 --> 00:08:35.470 as the human cry from the public on their charges 00:08:35.470 --> 00:08:38.343 that they were experiencing was starting to flare up. 00:08:39.420 --> 00:08:41.770 Well, now we have taken action. 00:08:41.770 --> 00:08:45.480 This Commission has adopted with legislative guidance 00:08:45.480 --> 00:08:47.010 and legislative tools. 00:08:47.010 --> 00:08:49.540 We have adopted a securitization framework 00:08:49.540 --> 00:08:50.560 and that's moving forward. 00:08:50.560 --> 00:08:53.200 My memo was designed to make sure that that is captured 00:08:53.200 --> 00:08:56.220 in the questions that should absolutely be addressed 00:08:56.220 --> 00:09:00.580 in these preliminary orders and for ALJ consideration 00:09:00.580 --> 00:09:03.360 as these topics move through the process. 00:09:03.360 --> 00:09:07.310 And that way we can get a good sightline 00:09:07.310 --> 00:09:09.720 on how these tools will be used for the benefit 00:09:09.720 --> 00:09:12.240 of the consumers that they were expressly designed 00:09:12.240 --> 00:09:13.073 to affect. 00:09:15.830 --> 00:09:16.750 Commissioner McAdams. 00:09:16.750 --> 00:09:20.090 Thank you so much for your leadership on this issue. 00:09:20.090 --> 00:09:21.290 This is an important issue. 00:09:21.290 --> 00:09:25.800 I think not just now, while I'm currently serving 00:09:25.800 --> 00:09:27.570 as a Commissioner here. 00:09:27.570 --> 00:09:29.070 These are issues I experienced 00:09:31.180 --> 00:09:33.914 when I was serving as public counsel at (indistinct). 00:09:33.914 --> 00:09:35.610 And we received many consumer calls 00:09:35.610 --> 00:09:39.290 from sort of larger commercial customers. 00:09:39.290 --> 00:09:40.630 Not really the smaller commercial, 00:09:40.630 --> 00:09:43.590 but just bigger than smaller commercial customers 00:09:43.590 --> 00:09:47.610 throughout the state that were getting ancillary 00:09:47.610 --> 00:09:49.047 service charges passed on to them. 00:09:49.047 --> 00:09:54.047 And in many times they were just huge, huge amounts. 00:09:55.832 --> 00:09:58.420 And it was really tough, you know, 00:09:58.420 --> 00:09:59.560 hearing those concerns. 00:09:59.560 --> 00:10:01.483 These were mom and pop businesses, 00:10:03.440 --> 00:10:08.350 that were getting $100,000 bill that no one can file 00:10:08.350 --> 00:10:09.290 for those types of bills. 00:10:09.290 --> 00:10:11.690 And while I recognize that many of the companies, 00:10:11.690 --> 00:10:14.160 and it was a handful of them that passed down these costs, 00:10:14.160 --> 00:10:16.110 or at least those are the calls we got, 00:10:17.680 --> 00:10:20.993 per their contract could pass these costs along. 00:10:22.000 --> 00:10:24.529 We've got to close the loopholes. 00:10:24.529 --> 00:10:26.393 And I think, you know, 00:10:27.850 --> 00:10:32.680 4492, house bill 4492 specifically provided 00:10:33.918 --> 00:10:35.920 a pathway for those customers to get a refund 00:10:35.920 --> 00:10:38.400 and a credit in our debt obligation order 00:10:38.400 --> 00:10:41.363 in Docket number 52322, 00:10:42.640 --> 00:10:44.010 an approval of a settlement agreement 00:10:44.010 --> 00:10:46.730 that requires the companies that get securitization 00:10:47.608 --> 00:10:49.270 financing to credit and refund the customers 00:10:49.270 --> 00:10:51.180 is extremely important. 00:10:51.180 --> 00:10:53.280 We've gotta provide that relief to those customers 00:10:53.280 --> 00:10:55.220 that got those causes passed on to them. 00:10:55.220 --> 00:10:57.690 And so I commend you for highlighting this issue 00:10:59.630 --> 00:11:02.780 since we might get more of these cases come before us. 00:11:02.780 --> 00:11:06.510 'Cause I know we encourage customers to file complaints 00:11:06.510 --> 00:11:07.730 just so they can get on the record. 00:11:07.730 --> 00:11:10.160 And at some point we can come up with some framework 00:11:10.160 --> 00:11:12.093 to address these issues. 00:11:12.093 --> 00:11:12.926 And here they are. 00:11:12.926 --> 00:11:16.740 Here's the first one with the complaint by BHC property 00:11:16.740 --> 00:11:19.200 management versus NG Resources. 00:11:19.200 --> 00:11:23.530 And so I would, if you will, 00:11:23.530 --> 00:11:25.260 ask even more specific questions 00:11:25.260 --> 00:11:30.260 so we can ensure that we get all of the information 00:11:32.210 --> 00:11:33.690 we need in the record. 00:11:33.690 --> 00:11:36.590 And I think your broader question is definitely important. 00:11:37.877 --> 00:11:40.170 If you will just kind of, you know, 00:11:40.170 --> 00:11:41.200 bear with me a little bit. 00:11:41.200 --> 00:11:42.619 Have at it. 00:11:42.619 --> 00:11:45.250 I would say that I think the first question 00:11:46.387 --> 00:11:49.390 should be what effect does the Commission's 00:11:49.390 --> 00:11:53.340 debt obligation order in docket number 52322 00:11:53.340 --> 00:11:54.260 have on this case? 00:11:54.260 --> 00:11:56.880 So, very similar to your broad question. 00:11:56.880 --> 00:11:59.000 'Cause I wanna tie it to the debt obligation order. 00:11:59.000 --> 00:12:01.430 'Cause that's where the requirements to refund 00:12:01.430 --> 00:12:06.430 and credit are specifically prescribed by the Commission 00:12:06.720 --> 00:12:10.367 and per HB 442. 00:12:10.367 --> 00:12:12.740 Second question I would ask is, 00:12:12.740 --> 00:12:17.740 is NG Resources LLC receiving securitization proceeds 00:12:18.270 --> 00:12:20.620 pursuant to the debt obligation order 00:12:20.620 --> 00:12:22.363 in docket number 52322. 00:12:25.420 --> 00:12:29.990 Third question is if so, is NG Resources LLC 00:12:29.990 --> 00:12:31.990 required to provide a refund or credit 00:12:31.990 --> 00:12:34.670 to its customers for ancillary service costs 00:12:34.670 --> 00:12:36.880 in excess of the system-wide offer cap 00:12:37.890 --> 00:12:40.490 and for reliability deployment price at our charges. 00:12:41.420 --> 00:12:44.373 And what is the amount of the refunded credit? 00:12:45.420 --> 00:12:48.470 So I wanna make sure that we get all this information 00:12:48.470 --> 00:12:50.853 in the record and as we get other cases, 00:12:52.039 --> 00:12:54.280 potentially other cases that involve reps 00:12:54.280 --> 00:12:55.113 that pass these costs down, 00:12:55.113 --> 00:12:56.220 and we just, you know, 00:12:56.220 --> 00:12:58.150 plug in the other company's name 00:12:58.150 --> 00:12:59.790 and we have these specific questions 00:12:59.790 --> 00:13:01.810 laid out in our preliminary order going forward 00:13:01.810 --> 00:13:06.810 so that we get the facts in the record that, you know, 00:13:07.500 --> 00:13:10.930 this rep hasn't opted out of 52322, 00:13:10.930 --> 00:13:14.330 and that they recognize the requirement to refund 00:13:14.330 --> 00:13:15.540 and credit their customer 00:13:15.540 --> 00:13:17.290 and how much they planned to do so. 00:13:18.140 --> 00:13:22.410 Can we edit your last question to include refund 00:13:22.410 --> 00:13:27.410 and/or provide long-term financing for any 00:13:28.290 --> 00:13:29.773 remaining obligations. 00:13:31.410 --> 00:13:33.310 If they put them up on a payment plan. 00:13:34.230 --> 00:13:36.823 Sure, however we wanna capture that. 00:13:38.430 --> 00:13:42.843 So, what is the amount of the refund or credit or... 00:13:45.470 --> 00:13:50.470 Any long-term financing or payment plan made available. 00:13:54.044 --> 00:13:54.877 Does that work? 00:13:54.877 --> 00:13:56.047 Yeah, I think so. 00:13:56.047 --> 00:13:58.209 So I would say just to help Steven a little bit is, 00:13:58.209 --> 00:14:00.063 what is the amount of the refund or credit, 00:14:02.130 --> 00:14:06.370 and also provide us with information 00:14:06.370 --> 00:14:10.170 on whether they are entering into payment plans 00:14:10.170 --> 00:14:12.190 with their customers that are owed a refund 00:14:12.190 --> 00:14:13.090 or credit as well. 00:14:13.090 --> 00:14:14.090 Or something along those lines. 00:14:14.090 --> 00:14:16.100 We can work with you offline. 00:14:16.100 --> 00:14:18.700 So I think we would ask are they required 00:14:18.700 --> 00:14:20.280 to provide a refund or a credit, 00:14:20.280 --> 00:14:22.680 that's the statutory directive. 00:14:22.680 --> 00:14:27.343 And then we could say, if so, what is this amount? 00:14:30.822 --> 00:14:34.440 And are you using a long-term financing 00:14:34.440 --> 00:14:38.510 or payment plan to recoup these amounts? 00:14:38.510 --> 00:14:39.798 Something like that? 00:14:39.798 --> 00:14:43.150 Making a long-term financing plan available to customers, 00:14:43.150 --> 00:14:44.710 or the customer. 00:14:44.710 --> 00:14:47.253 We may have to just make that a separate question. 00:14:48.194 --> 00:14:49.540 A sub-question. 00:14:49.540 --> 00:14:50.373 Sure. 00:14:52.980 --> 00:14:56.030 Yeah, that'd be good information. 00:14:56.030 --> 00:14:58.743 Yeah, both of y'all are asking important questions. 00:14:59.809 --> 00:15:03.510 Are you comfortable adding the association to the dead order 00:15:05.910 --> 00:15:07.610 to our question with her question? 00:15:09.601 --> 00:15:10.570 Tighten that up. 00:15:10.570 --> 00:15:11.894 Yep. 00:15:11.894 --> 00:15:13.050 And thank you for your consideration, 00:15:13.050 --> 00:15:13.980 Commissioner McAdams. 00:15:13.980 --> 00:15:16.560 Again, I really do thank you for raising this issue. 00:15:16.560 --> 00:15:19.930 It is a very important issue and for being open 00:15:19.930 --> 00:15:23.330 to my additional specific questions and Chairman Lake 00:15:23.330 --> 00:15:25.040 for your additional question. 00:15:25.040 --> 00:15:26.560 Thanks, Commissioner. 00:15:30.706 --> 00:15:31.539 All right. 00:15:31.539 --> 00:15:32.440 Is there a motion to approve the preliminary order 00:15:32.440 --> 00:15:35.210 with the addition of the questions outlined 00:15:35.210 --> 00:15:37.220 from the dias today? 00:15:37.220 --> 00:15:38.053 So moved. 00:15:38.053 --> 00:15:38.886 Second. 00:15:38.886 --> 00:15:40.118 All in favor, say aye. 00:15:40.118 --> 00:15:40.951 [Commissioners together] Aye. 00:15:40.951 --> 00:15:41.784 Motion passes. 00:15:44.380 --> 00:15:47.100 That brings us to item 19. 00:15:47.100 --> 00:15:49.916 I believe Commissioner Glotfelty, 00:15:49.916 --> 00:15:52.800 you've got a few things to discuss on this one. 00:15:52.800 --> 00:15:55.080 Thank you, Mr. Chairman. 00:15:55.080 --> 00:15:58.740 I did request that project number 46304 00:15:58.740 --> 00:16:01.080 be added to the docket today. 00:16:01.080 --> 00:16:04.150 As a little background, 00:16:04.150 --> 00:16:07.083 one of my first meetings a few months ago. 00:16:08.430 --> 00:16:11.150 So Commissioner Cobos was talking about the expansion 00:16:11.150 --> 00:16:12.550 of transmission. 00:16:12.550 --> 00:16:14.960 One of the issues that what was brought up 00:16:14.960 --> 00:16:19.650 that we discussed during that open meeting was 00:16:19.650 --> 00:16:21.513 the Southern cross-transmission line. 00:16:24.836 --> 00:16:26.160 The chairman suggested that I do a little bit 00:16:26.160 --> 00:16:28.340 of research into this and try to figure something out. 00:16:28.340 --> 00:16:31.790 And I'm happy to report that I've kind of figured 00:16:31.790 --> 00:16:34.240 a little bit of it out, but not the entire thing. 00:16:35.390 --> 00:16:38.013 Thus, I have a path forward. 00:16:39.670 --> 00:16:42.490 So this project has been in regulatory review 00:16:42.490 --> 00:16:45.760 for seven years, which is a long time. 00:16:45.760 --> 00:16:47.760 I'm not saying that we have all of the information 00:16:47.760 --> 00:16:49.013 to make decisions yet. 00:16:50.040 --> 00:16:50.873 ERCOT hasn't completed 00:16:50.873 --> 00:16:54.240 their review of all of the directives that we gave them 00:16:54.240 --> 00:16:56.120 in the original order. 00:16:56.120 --> 00:16:57.110 There are four remaining. 00:16:57.110 --> 00:16:59.801 I think two of those can be done now 00:16:59.801 --> 00:17:02.201 and two of them have to be done at a later time. 00:17:03.182 --> 00:17:06.530 And I think there are other areas that parties 00:17:06.530 --> 00:17:10.090 have suggested that need some attention from us, 00:17:10.090 --> 00:17:14.420 including a revision or a look at the export tariff 00:17:14.420 --> 00:17:18.323 and the cost of that as well as more in general, 00:17:21.580 --> 00:17:23.593 the transmission planning for DC ties. 00:17:26.521 --> 00:17:29.930 What I propose is that we ask parties 00:17:33.410 --> 00:17:36.720 that are in this docket to come and tell us 00:17:36.720 --> 00:17:38.150 what the path forward is. 00:17:38.150 --> 00:17:39.310 There are a lot of things 00:17:39.310 --> 00:17:41.480 that are actually going on on this. 00:17:41.480 --> 00:17:45.630 ERCOT has given us their ninth status report 00:17:45.630 --> 00:17:46.723 a few weeks ago. 00:17:48.140 --> 00:17:52.670 The committees at ERCOT are working through the issues. 00:17:52.670 --> 00:17:57.670 But I don't yet have a path forward that I can say, 00:17:58.400 --> 00:18:00.900 this is what we need to do, A, B and C. 00:18:00.900 --> 00:18:02.800 I think we need to do that together. 00:18:02.800 --> 00:18:05.520 But I think if we can get the parties to file 00:18:05.520 --> 00:18:07.680 what they think the next steps are, 00:18:07.680 --> 00:18:10.020 it will let us narrow down that funnel of the issues 00:18:10.020 --> 00:18:12.320 that we absolutely have to address. 00:18:12.320 --> 00:18:16.160 Projects like this that are not rate-based projects, 00:18:16.160 --> 00:18:19.683 kind of live and die in regulatory limbo. 00:18:20.670 --> 00:18:22.540 It's private capital that's being spent. 00:18:22.540 --> 00:18:24.023 And it's my view that, 00:18:26.930 --> 00:18:28.200 if it's in the public interest, 00:18:28.200 --> 00:18:32.060 we should ensure that we resolve our issues 00:18:32.060 --> 00:18:34.840 so that the private capital can be spent 00:18:34.840 --> 00:18:37.030 or the private capital will go somewhere else. 00:18:37.030 --> 00:18:38.830 And either one of those is okay. 00:18:38.830 --> 00:18:41.000 That's the market, that's supposed to decide that, 00:18:41.000 --> 00:18:46.000 but the regulatory responsibility and the ERCOT review 00:18:46.780 --> 00:18:51.130 are things that we can speed up finalize, and be done with. 00:18:51.130 --> 00:18:54.090 And so it's my recommendation, again, 00:18:54.090 --> 00:18:56.500 that we ask parties to come forth, 00:18:56.500 --> 00:18:58.560 tell us what the steps are that have to be done 00:18:58.560 --> 00:19:00.190 to be completed. 00:19:00.190 --> 00:19:02.830 And then we can not take action on those, 00:19:02.830 --> 00:19:03.993 whatever's proposed. 00:19:05.650 --> 00:19:07.490 Makes sense to me. 00:19:07.490 --> 00:19:09.400 Yeah, no, thank you, Mr. Chairman. 00:19:09.400 --> 00:19:12.750 If I may ask a question just to crystallize that. 00:19:12.750 --> 00:19:14.240 And frankly, on his face, 00:19:14.240 --> 00:19:16.400 I think this is gonna be helpful. 00:19:16.400 --> 00:19:20.407 So the update, you know, 00:19:20.407 --> 00:19:21.770 and we've all received updates 00:19:21.770 --> 00:19:24.980 and we've received updates officially, but again, 00:19:24.980 --> 00:19:29.060 I think we are very close to ERCOT finalizing 00:19:29.060 --> 00:19:31.270 their portion of the review. 00:19:31.270 --> 00:19:34.400 And there's an ERCOT responsibility portion 00:19:34.400 --> 00:19:36.560 as per the directives that the Commission adopt, 00:19:36.560 --> 00:19:38.080 a statutorily authorized. 00:19:38.080 --> 00:19:40.530 And then there's sort of also a non-ERCOT, 00:19:40.530 --> 00:19:42.370 the other side of the border portion. 00:19:42.370 --> 00:19:46.750 So your intent is that the update could help clarify 00:19:46.750 --> 00:19:48.810 what is remaining on our side of the border, 00:19:48.810 --> 00:19:50.820 and then what is up to those counterparties 00:19:50.820 --> 00:19:52.400 on the other side? 00:19:52.400 --> 00:19:53.340 Absolutely. 00:19:53.340 --> 00:19:55.560 So, what I want to do is make sure 00:19:55.560 --> 00:19:58.880 that it's crystal clear what ERCOT has to do, 00:19:58.880 --> 00:20:00.270 what the applicant has to do, 00:20:00.270 --> 00:20:01.190 and what we have to do. 00:20:01.190 --> 00:20:02.140 I'm all for that. 00:20:03.460 --> 00:20:04.293 Sure, yeah. 00:20:04.293 --> 00:20:05.980 And timeframes to get them resolved. 00:20:08.170 --> 00:20:10.890 No, I just, you know, thank you for the update 00:20:10.890 --> 00:20:12.690 and your diligence on this issue. 00:20:12.690 --> 00:20:13.900 I think it's important. 00:20:13.900 --> 00:20:15.340 I mean, it has been several years 00:20:15.340 --> 00:20:17.980 and to maybe level set to see where we're at 00:20:17.980 --> 00:20:19.780 and, you know, have a roadmap of anything 00:20:19.780 --> 00:20:24.690 that ERCOT or the Commission could do to, you know, 00:20:24.690 --> 00:20:29.473 at least do our end of doing the due diligence on this tie. 00:20:30.440 --> 00:20:33.250 What form would this take in practice? 00:20:33.250 --> 00:20:35.760 The form would be for them to file 00:20:35.760 --> 00:20:39.433 within the existing docket, which is 46304. 00:20:40.690 --> 00:20:43.960 They would file information within that docket. 00:20:43.960 --> 00:20:47.250 And since it's already open-- 00:20:47.250 --> 00:20:50.900 Do you want to file a list of specific questions 00:20:50.900 --> 00:20:53.520 or scope of questions, or you wanna just have them 00:20:53.520 --> 00:20:54.353 respond to your-- 00:20:54.353 --> 00:20:56.120 I think the record is clear. 00:20:56.120 --> 00:20:58.450 They know what needs to happen between now 00:20:58.450 --> 00:21:00.490 and when they're finally approved. 00:21:00.490 --> 00:21:01.833 Just let us know that. 00:21:02.700 --> 00:21:03.970 Again, all three parties. 00:21:03.970 --> 00:21:04.820 Keep it simple. 00:21:05.990 --> 00:21:07.323 All right. 00:21:07.323 --> 00:21:08.390 So you just wanna leave it this informal 00:21:08.390 --> 00:21:09.680 then file when they want to, 00:21:09.680 --> 00:21:12.100 or do you wanna issue an order of this got timelines 00:21:12.100 --> 00:21:13.013 and requirements? 00:21:14.600 --> 00:21:15.433 I'd rather-- 00:21:15.433 --> 00:21:16.340 Strong guidance from the dais. 00:21:16.340 --> 00:21:17.930 I'd like it before the end of the year. 00:21:17.930 --> 00:21:20.200 I mean, this all plays into market redesign as well. 00:21:20.200 --> 00:21:22.830 I would like it sooner than the end of the year. 00:21:22.830 --> 00:21:25.530 I'd like it within 30 days, if we can get it. 00:21:25.530 --> 00:21:28.210 I think a lot of the stuff they're working on now, 00:21:28.210 --> 00:21:30.580 so having something filed with the Commission 00:21:30.580 --> 00:21:32.563 shouldn't be a huge lift. 00:21:33.690 --> 00:21:38.620 Does that require an order or does that require a... 00:21:38.620 --> 00:21:40.370 Take an order might be useful. 00:21:40.370 --> 00:21:42.650 'Cause it'd be nice to know 3000 megawatts 00:21:42.650 --> 00:21:45.310 of DC capability we're gonna play in this whole market 00:21:45.310 --> 00:21:46.660 as we start moving forward. 00:21:48.858 --> 00:21:52.543 So, how would I propose an order to do that? 00:21:54.660 --> 00:21:57.470 We order what we just discussed? 00:21:57.470 --> 00:22:02.470 Yes, tell me to go draft you in order and make a motion 00:22:02.690 --> 00:22:05.768 to so do so and then vote on it. 00:22:05.768 --> 00:22:06.601 And we'll go do so. 00:22:06.601 --> 00:22:09.053 I would suggest that you draft a memo. 00:22:09.930 --> 00:22:11.170 Can you make a motion? 00:22:11.170 --> 00:22:14.120 I make a motion that Stephen drafts a memo, 00:22:14.120 --> 00:22:18.173 the staff drafts a memo, an order, excuse me, 00:22:19.337 --> 00:22:22.660 an order outlining the issues that we just discussed here 00:22:22.660 --> 00:22:26.340 and that parties file comments back, answering the issues 00:22:26.340 --> 00:22:28.308 we discussed within 30 days. 00:22:28.308 --> 00:22:29.896 And I would second. 00:22:29.896 --> 00:22:31.388 30 days of today. 00:22:31.388 --> 00:22:34.925 So we've got a motion and a second. 00:22:34.925 --> 00:22:36.370 30 days of the date the order goes out. 00:22:36.370 --> 00:22:38.070 30 days from the date the order goes out. 00:22:38.070 --> 00:22:40.313 Okay, you got a motion and a second. 00:22:41.870 --> 00:22:43.449 All in favor, say aye. 00:22:43.449 --> 00:22:44.282 [Commissioners together] Aye. 00:22:44.282 --> 00:22:45.410 Motion passes. 00:22:45.410 --> 00:22:46.243 There we go. 00:22:50.320 --> 00:22:53.610 Next item 20 and 21. 00:22:53.610 --> 00:22:55.410 I don't have anything on those items. 00:22:55.410 --> 00:22:56.633 Do y'all? I don't think so. 00:22:57.709 --> 00:23:01.410 It brings us to item 22. 00:23:01.410 --> 00:23:03.023 We've got a staff memo. 00:23:05.370 --> 00:23:07.610 So 22 is project 52307. 00:23:07.610 --> 00:23:09.950 It's a review of the rules of ERCOT. 00:23:09.950 --> 00:23:12.810 Staff filed up a memo 00:23:12.810 --> 00:23:14.540 discussing some actions of ERCOT 00:23:14.540 --> 00:23:17.340 with a proposed order for the Commission 00:23:17.340 --> 00:23:20.440 to approve those actions of the ERCOT board. 00:23:20.440 --> 00:23:22.900 And for background for those folks watching at home, 00:23:22.900 --> 00:23:25.560 these are the items that were approved 00:23:25.560 --> 00:23:28.640 with the most recent ERCOT board meeting. 00:23:28.640 --> 00:23:30.358 I think it's pretty straight forward 00:23:30.358 --> 00:23:31.490 and it's been well vetted. 00:23:31.490 --> 00:23:33.610 At this point, the only thing I would mention 00:23:33.610 --> 00:23:37.547 is that in addition to NPR 1093 and OBDER, 00:23:45.050 --> 00:23:46.810 sorry, NPR 1093. 00:23:46.810 --> 00:23:50.870 In addition to that bringing more load into play 00:23:50.870 --> 00:23:53.114 for our non spend resources 00:23:53.114 --> 00:23:58.100 would emphasize the importance of NPR 1101 00:23:58.100 --> 00:23:59.750 as a follow-up on that 00:23:59.750 --> 00:24:02.850 to ensure that those resources are deployed 00:24:02.850 --> 00:24:04.320 in a resource agnostic way 00:24:05.750 --> 00:24:08.040 as soon as possible after implementation 00:24:08.040 --> 00:24:10.440 of that new load resource. 00:24:10.440 --> 00:24:13.700 So we will be enhancing our margin of safety 00:24:13.700 --> 00:24:16.630 and doing it in a resource neutral way, 00:24:16.630 --> 00:24:21.630 encouraged stakeholders to continue moving NPR 1101 00:24:21.740 --> 00:24:26.003 through the process with all alacrity. 00:24:27.860 --> 00:24:30.330 Is there a motion to, or any other thoughts or questions 00:24:30.330 --> 00:24:32.140 or a motion to approve the proposed order? 00:24:32.140 --> 00:24:33.170 So moved. 00:24:33.170 --> 00:24:34.003 Second. 00:24:34.003 --> 00:24:35.401 All in favor, say aye. 00:24:35.401 --> 00:24:36.440 [Commissioner together] Aye. 00:24:36.440 --> 00:24:37.785 None opposed. 00:24:37.785 --> 00:24:38.950 Motion passes. 00:24:38.950 --> 00:24:43.950 Item 23 regarding statutory definitions. 00:24:45.840 --> 00:24:48.133 Would Mr. Smelser please approach? 00:24:57.800 --> 00:24:58.650 Chairman, Commissioners, 00:24:58.650 --> 00:25:00.250 David Smelser, Commission staff. 00:25:02.060 --> 00:25:03.380 Today we have a simple PFP. 00:25:03.380 --> 00:25:06.030 This is just a box-checking rulemaking 00:25:06.030 --> 00:25:07.730 where there's a number of statutes 00:25:07.730 --> 00:25:10.580 that were passed that can be implemented by us 00:25:10.580 --> 00:25:12.820 just updating our definitions to match the definitions 00:25:12.820 --> 00:25:13.653 and statute. 00:25:15.271 --> 00:25:16.440 An example of the sorts of things that are involved 00:25:16.440 --> 00:25:18.660 is for instance, if you're a electric vehicle 00:25:18.660 --> 00:25:22.470 charging station, you no longer gotta have a rep certificate 00:25:22.470 --> 00:25:23.303 or electric utility. 00:25:23.303 --> 00:25:24.573 It's stuff like that. 00:25:24.573 --> 00:25:27.610 And then there's some code cleanup items 00:25:27.610 --> 00:25:29.190 that we just do whenever we open these roles. 00:25:29.190 --> 00:25:32.790 So it's a pretty simple, generally non-substantive 00:25:32.790 --> 00:25:36.293 rulemaking just to move forward on some of this legislation. 00:25:37.290 --> 00:25:38.620 Appreciate your diligence on it. 00:25:38.620 --> 00:25:40.280 Any questions, comments? 00:25:40.280 --> 00:25:42.643 Well done, copy and pasting from the statute. 00:25:43.610 --> 00:25:44.460 Happy to do it. 00:25:47.140 --> 00:25:49.983 You're very diligent and thorough copying and pasting. 00:25:51.450 --> 00:25:53.950 I actually made Christine do it before she left. 00:25:54.940 --> 00:25:56.830 I needed a little help on the copy-paste. 00:25:56.830 --> 00:25:57.870 There you go. 00:25:57.870 --> 00:26:00.400 Is there a motion to approve the proposal for publications. 00:26:00.400 --> 00:26:01.233 So moved. 00:26:01.233 --> 00:26:02.558 Second. 00:26:02.558 --> 00:26:03.391 All in favor, say aye. 00:26:03.391 --> 00:26:04.224 [Commissioners together] Aye. 00:26:04.224 --> 00:26:05.057 Mr. Chairman. 00:26:05.057 --> 00:26:05.890 Yes. 00:26:05.890 --> 00:26:06.930 This is an item that we didn't include 00:26:06.930 --> 00:26:09.950 in our list of issues to deal with the Consent Agenda. 00:26:09.950 --> 00:26:12.720 Is this the type of item you'd like us to add to that? 00:26:12.720 --> 00:26:15.320 I can do a revision to that, bring it back to y'all. 00:26:16.874 --> 00:26:18.143 I certainly wouldn't be opposed to that. 00:26:19.186 --> 00:26:20.140 Would not be opposed. 00:26:20.140 --> 00:26:20.990 Did I lose money? 00:26:22.678 --> 00:26:24.728 I had a bet going on with Steven on this. 00:26:28.012 --> 00:26:30.089 Not a bet about me asking y'all if y'all wanted to do it, 00:26:30.089 --> 00:26:30.922 but... 00:26:30.922 --> 00:26:32.933 I'm sure we can take that offline. 00:26:37.770 --> 00:26:42.250 I appreciate a revision as described to that. 00:26:42.250 --> 00:26:45.773 I will bring it to you as time allows. 00:26:46.940 --> 00:26:47.773 Appreciate it. 00:26:49.150 --> 00:26:49.983 All right. 00:26:50.940 --> 00:26:52.790 That will bring us to item number 24. 00:26:54.190 --> 00:26:58.723 We have a couple items Commissioner McAdams filed in memos. 00:26:59.741 --> 00:27:01.500 So I'll ask him to lay that out fo us. 00:27:01.500 --> 00:27:02.660 Yes, sir. 00:27:02.660 --> 00:27:05.340 And welcome feedback. 00:27:05.340 --> 00:27:07.103 This memo is again, 00:27:09.360 --> 00:27:11.200 I'm very proud of my staff. 00:27:11.200 --> 00:27:13.173 They keep it concise, 00:27:14.750 --> 00:27:16.240 and that's intentional. 00:27:16.240 --> 00:27:19.478 This memo is the product of stakeholder conversations, 00:27:19.478 --> 00:27:22.610 conversations from this dais in previous workgroups 00:27:22.610 --> 00:27:27.610 about the concept of prioritizing dispatchable resources 00:27:27.930 --> 00:27:30.703 within the transmission interconnection queue. 00:27:32.180 --> 00:27:36.660 I will highlight a couple of concepts here 00:27:39.220 --> 00:27:42.988 and note that it is... 00:27:42.988 --> 00:27:43.920 And my memo can speak for itself, 00:27:43.920 --> 00:27:48.210 but it is my belief that this prioritization 00:27:48.210 --> 00:27:53.210 does not necessarily push any resource to a back of a line 00:27:54.490 --> 00:27:57.513 or cause them to restart a process. 00:27:59.520 --> 00:28:01.240 This is policy is designed frankly, 00:28:01.240 --> 00:28:05.410 to provide guidance to transmission service providers 00:28:05.410 --> 00:28:10.140 in the event of a real land rush, 00:28:10.140 --> 00:28:11.890 for lack of better words, 00:28:11.890 --> 00:28:15.453 in resource interconnection interests. 00:28:18.140 --> 00:28:20.973 Scenarios, like when Chris was built, 00:28:22.420 --> 00:28:23.253 always present themselves. 00:28:23.253 --> 00:28:25.930 Whenever new transmission lines are built that open up 00:28:25.930 --> 00:28:28.750 vast territories that offer good resources 00:28:28.750 --> 00:28:31.540 for Texas consumers and ERCOT 00:28:31.540 --> 00:28:33.633 to gain new resources for the system. 00:28:34.681 --> 00:28:37.480 There's always a surge of interest in interconnection. 00:28:37.480 --> 00:28:39.280 To be ahead of that, 00:28:39.280 --> 00:28:41.740 as in case and point, we've discussed before 00:28:41.740 --> 00:28:43.200 the lower Rio Grande valley, 00:28:43.200 --> 00:28:46.220 whenever that area becomes available 00:28:46.220 --> 00:28:49.540 to developers, resource developers, generators. 00:28:49.540 --> 00:28:51.790 There's gonna be strong interest in that area 00:28:52.731 --> 00:28:53.580 to deploy quickly. 00:28:53.580 --> 00:28:56.330 And our transmission service providers 00:28:56.330 --> 00:29:00.150 need to have some type of guidance from this Commission 00:29:00.150 --> 00:29:03.283 on what is important to take up first. 00:29:05.527 --> 00:29:08.488 And that's the overarching policy of the memo. 00:29:08.488 --> 00:29:13.488 It prioritizes in steps what you should look at first, 00:29:13.900 --> 00:29:15.533 second, and then third. 00:29:16.410 --> 00:29:20.590 It also allows flexibility for ERCOT. 00:29:20.590 --> 00:29:23.090 Again, I'm trying to keep this policy high level 00:29:23.090 --> 00:29:25.790 so that we don't have any unintended consequences 00:29:25.790 --> 00:29:28.480 of being too specific in our instruction, 00:29:28.480 --> 00:29:31.030 but I would like the experts at ERCOT 00:29:31.030 --> 00:29:33.300 to have the flexibility to determine 00:29:34.630 --> 00:29:39.630 how a battery within that two-hour dispatchability parameter 00:29:40.920 --> 00:29:42.230 can play into that. 00:29:42.230 --> 00:29:45.910 As you've said, Mr. Chairman, you can tie them together. 00:29:45.910 --> 00:29:46.930 You can scale them up. 00:29:46.930 --> 00:29:49.900 You can use them in a modular way. 00:29:49.900 --> 00:29:51.010 Physically or financially. 00:29:51.010 --> 00:29:51.850 That's right. 00:29:51.850 --> 00:29:56.410 I do not wanna discourage battery deployment 00:29:58.132 --> 00:30:00.160 to not request the full extent 00:30:00.160 --> 00:30:02.710 of their technical capabilities in their interconnection. 00:30:02.710 --> 00:30:04.703 We want the full megawatts. 00:30:05.580 --> 00:30:08.620 But ultimately we also want them to be able to cover, 00:30:08.620 --> 00:30:11.550 which is in our interest over the next several years 00:30:11.550 --> 00:30:13.560 to cover a full two-hour period, 00:30:13.560 --> 00:30:15.290 because that's what ERCOT is telling us 00:30:15.290 --> 00:30:18.650 that we're desperately going to need in the near future. 00:30:18.650 --> 00:30:22.530 And so from a standpoint of giving the engineers 00:30:22.530 --> 00:30:23.877 at ERCOT the ability to say, 00:30:23.877 --> 00:30:26.620 "All right two hour capability." 00:30:26.620 --> 00:30:29.930 But and your applying for 100 megawatt 00:30:29.930 --> 00:30:32.129 battery interconnection, 00:30:32.129 --> 00:30:33.530 'cause that's what you think you're gonna need 00:30:33.530 --> 00:30:35.110 on this project, 00:30:35.110 --> 00:30:39.180 but we're talking about a two hour discharge capability 00:30:39.180 --> 00:30:41.920 of 50 megawatts for two hours. 00:30:41.920 --> 00:30:45.030 Then I want them to have the flexibility to front-load that 00:30:45.030 --> 00:30:47.870 'cause 50 megawatts for two hours is gonna come in 00:30:47.870 --> 00:30:50.530 real handy in 2023, I'm sure. 00:30:50.530 --> 00:30:52.620 Hopefully or 2024. 00:30:52.620 --> 00:30:55.510 So again, I wanna allow that flexibility, 00:30:55.510 --> 00:30:59.080 but still prioritize on a reasonable basis 00:30:59.080 --> 00:31:01.170 in the event that we have a panacea 00:31:02.020 --> 00:31:04.760 of generators wanting to get into the ERCOT market 00:31:04.760 --> 00:31:07.653 after our market reforms go into effect. 00:31:09.190 --> 00:31:11.780 I realized there's been some discussion 00:31:11.780 --> 00:31:16.780 about TAC and our governing rules. 00:31:18.470 --> 00:31:23.470 I still having reviewed TAC Chapter 25, 196 and so on. 00:31:25.210 --> 00:31:28.700 I believe that we have the flexibility to prioritize still 00:31:28.700 --> 00:31:33.317 in interconnection and I'll leave it at that, 00:31:33.317 --> 00:31:36.580 but I welcome any conversation on this topic. 00:31:36.580 --> 00:31:39.550 Sure, I've got a couple questions on there. 00:31:39.550 --> 00:31:41.070 I'm sure colleagues do as well. 00:31:41.070 --> 00:31:43.320 So I'll open it up for questions or comments. 00:31:44.930 --> 00:31:46.137 Go ahead, Mr. Chair. 00:31:49.280 --> 00:31:53.280 I like what you laid out here and I'm very grateful 00:31:53.280 --> 00:31:55.250 for you grabbing this bull by the horns. 00:31:55.250 --> 00:31:57.200 It's something that needs to be addressed 00:31:57.200 --> 00:32:01.053 and is an important step forward. 00:32:03.210 --> 00:32:05.200 More on the more logistical side. 00:32:05.200 --> 00:32:06.033 Yes, sir. 00:32:06.980 --> 00:32:08.920 On your second bullet point 00:32:08.920 --> 00:32:11.550 and I agree philosophically with your sequencing 00:32:12.760 --> 00:32:14.560 of everybody's resources and projects, 00:32:14.560 --> 00:32:16.390 co-located with inverter based resources 00:32:16.390 --> 00:32:19.963 that maybe dispatch for two or more hours. 00:32:23.435 --> 00:32:25.970 Is the entire project gonna be included 00:32:25.970 --> 00:32:28.410 in that second traunch of prioritization 00:32:28.410 --> 00:32:31.820 or just the capacity that is associated 00:32:31.820 --> 00:32:33.400 with dispatchability? 00:32:33.400 --> 00:32:34.810 No, sir, the entire project. 00:32:34.810 --> 00:32:37.100 Again, we want, in my view 00:32:37.100 --> 00:32:41.163 and this is where we need to iron out the logistics of that. 00:32:43.370 --> 00:32:46.200 The intent is to give a market signal of desirability 00:32:46.200 --> 00:32:47.520 of performance. 00:32:47.520 --> 00:32:50.160 And again, a market signal that those resources 00:32:50.160 --> 00:32:53.040 that are in queue should have every reason to go out 00:32:53.040 --> 00:32:57.530 and procure a dispatchable component to their project, 00:32:58.740 --> 00:33:00.800 either a wind farm or a solar farm. 00:33:00.800 --> 00:33:05.150 And so in my view, it's in our interest to insent 00:33:05.150 --> 00:33:06.500 every bit that we can get. 00:33:06.500 --> 00:33:09.900 And so it should be able to qualify that entire project 00:33:09.900 --> 00:33:13.150 under the dispatchability of that battery. 00:33:14.087 --> 00:33:17.680 In anticipation of gamesmanship. 00:33:17.680 --> 00:33:18.513 Yes, sir. 00:33:19.833 --> 00:33:23.600 Along the lines of a one megawatt two hour 00:33:23.600 --> 00:33:26.070 dispatchable battery attached to 100 megawatt 00:33:26.070 --> 00:33:27.830 or 1,000 megawatt wind farm. 00:33:27.830 --> 00:33:28.663 Yes, sir. 00:33:28.663 --> 00:33:30.653 Doesn't really solve what we're aiming for. 00:33:32.271 --> 00:33:34.940 Would you consider some sort of minimum hurdle 00:33:34.940 --> 00:33:39.940 of associated two hour or more storage, like 30, 50, 00:33:40.230 --> 00:33:42.290 60% thing to say that you can't just 00:33:43.270 --> 00:33:45.710 put a battery in the corner and qualify. 00:33:45.710 --> 00:33:48.310 So it's gotta be real, real numbers. 00:33:48.310 --> 00:33:50.010 It's gotta be real dispatchability. 00:33:50.010 --> 00:33:55.010 Yeah, if we were to consider that the ITC, 00:33:55.505 --> 00:33:59.040 the investment tax credit has a threshold for solar 00:33:59.040 --> 00:34:04.040 and it's 75% of the energy produced from that, 00:34:05.930 --> 00:34:10.630 I believe that might be the recoupment threshold. 00:34:10.630 --> 00:34:13.067 They take at least 75% of the energy 00:34:13.067 --> 00:34:15.870 that's gonna be discharged from that battery 00:34:15.870 --> 00:34:18.833 from that project that it's co located with. 00:34:20.750 --> 00:34:22.030 I don't know off the top of my head. 00:34:22.030 --> 00:34:25.093 Yeah, my understanding of the ITC is just basically, 00:34:26.822 --> 00:34:28.480 it's a tax credit and the last time I looked at it, 00:34:28.480 --> 00:34:33.480 which has been a little while it was 30% out of the project. 00:34:33.610 --> 00:34:35.910 So like if you had a $100,000 project, 00:34:35.910 --> 00:34:38.280 30% tax credit so that you wouldn't be giving 00:34:38.280 --> 00:34:39.820 to the federal government. 00:34:39.820 --> 00:34:40.680 Offsetting other income. 00:34:40.680 --> 00:34:42.350 But my point is that the federal government 00:34:42.350 --> 00:34:47.350 will pay for the battery if they take up to 75% 00:34:47.400 --> 00:34:52.040 of the energy that's dispatched from that battery 00:34:52.040 --> 00:34:54.120 from the co-located solar farm. 00:34:54.120 --> 00:34:56.130 So it gets bundled in. 00:34:56.130 --> 00:34:58.370 And so in order to have a consistent policy approach 00:34:58.370 --> 00:34:59.900 and thus get more. 00:34:59.900 --> 00:35:00.810 Yes, sir. 00:35:00.810 --> 00:35:01.984 Very good. 00:35:01.984 --> 00:35:04.660 So you qualifies for bullet point to the second level 00:35:04.660 --> 00:35:06.440 of prioritization if... 00:35:08.980 --> 00:35:09.813 It's not working well. 00:35:09.813 --> 00:35:13.070 The batteries total capacity equals 75% of the project 00:35:13.070 --> 00:35:15.460 or more of the project that is co-located. 00:35:15.460 --> 00:35:16.293 Okay. 00:35:18.030 --> 00:35:21.320 That makes a lot of sense and appreciate your consistency 00:35:21.320 --> 00:35:22.550 with federal policy. 00:35:22.550 --> 00:35:25.110 I'm trying to line this up somehow. 00:35:25.110 --> 00:35:28.200 The second question is both a question and a comment 00:35:30.240 --> 00:35:35.240 about the two hour or more dispatchability requirement. 00:35:38.028 --> 00:35:41.210 If you're comfortable and the operations team 00:35:41.210 --> 00:35:42.785 at ERCOT is comfortable with that, 00:35:42.785 --> 00:35:44.730 there's been a debate about that. 00:35:44.730 --> 00:35:48.410 Then I'll defer to the operational experts on that, 00:35:48.410 --> 00:35:50.770 but I wanna make sure that we are putting 00:35:50.770 --> 00:35:55.060 the operational need first and we're not letting 00:35:55.060 --> 00:35:59.780 the current available technology just because we've got it, 00:35:59.780 --> 00:36:04.593 let's make that fit into a wag the dog or operational need, 00:36:06.540 --> 00:36:07.980 because first and foremost, 00:36:07.980 --> 00:36:11.970 we can't sacrifice operational reliability 00:36:13.050 --> 00:36:16.263 just so we can fit a round peg into a square hole. 00:36:18.080 --> 00:36:21.300 And secondly and just as importantly, 00:36:21.300 --> 00:36:24.730 is that the way to incentive... 00:36:24.730 --> 00:36:28.650 I mean, the way to incentivize continued 00:36:28.650 --> 00:36:33.330 and more aggressive development of these technologies 00:36:33.330 --> 00:36:38.300 is to set the higher standard and put the incentives there 00:36:38.300 --> 00:36:41.053 so the technology needs to match our operational needs, 00:36:43.017 --> 00:36:44.140 not matching the incentive 00:36:44.140 --> 00:36:46.673 to what the market already provides. 00:36:47.620 --> 00:36:50.220 I'll defer to you in the operational team at ERCOT 00:36:50.220 --> 00:36:53.943 on what that hour requirement, minimum hour requirement is. 00:36:55.160 --> 00:36:58.600 But I certainly do not want in a year or two 00:36:58.600 --> 00:37:02.970 to be hearing about how we don't our dispatchability 00:37:02.970 --> 00:37:04.763 doesn't cover the full duck curve. 00:37:06.730 --> 00:37:08.540 And that's not a comment to you, 00:37:08.540 --> 00:37:12.000 that's a comment that the battery industry. 00:37:12.000 --> 00:37:13.970 I don't think any of us wanna be getting those calls 00:37:13.970 --> 00:37:18.970 saying we're dangerously tight in our grid conditions today 00:37:20.320 --> 00:37:22.820 because two hours turns out not to be long enough. 00:37:24.290 --> 00:37:26.230 So let's maintain that operational reliability 00:37:26.230 --> 00:37:28.530 principle first and work backwards from there. 00:37:30.870 --> 00:37:33.323 We don't need to solve it today, but like I said, 00:37:33.323 --> 00:37:34.156 I just wanna... 00:37:34.156 --> 00:37:36.790 Philosophically, if you're looking for another vote 00:37:36.790 --> 00:37:39.967 on any type of concept, I would vote for that. 00:37:39.967 --> 00:37:41.370 I support that. 00:37:41.370 --> 00:37:44.070 That is the basis for this entire prioritization. 00:37:44.070 --> 00:37:46.140 Again, we're trying to give a market signal 00:37:46.140 --> 00:37:49.840 that supports our operational reliability on the system. 00:37:49.840 --> 00:37:52.900 So at this time anecdote, 00:37:52.900 --> 00:37:54.840 I mean, that's what we've heard we need, 00:37:54.840 --> 00:37:58.020 but again, that's not a statement 00:37:58.020 --> 00:38:00.400 that this isn't gonna evolve. 00:38:00.400 --> 00:38:02.640 I mean, it needs to be able to evolve 00:38:02.640 --> 00:38:05.990 and we have to be able to adapt with that. 00:38:07.967 --> 00:38:08.800 And Commissioner McAdams, 00:38:08.800 --> 00:38:10.500 thank you for your update on the memo. 00:38:11.800 --> 00:38:14.340 We had several discussions about this topic 00:38:14.340 --> 00:38:16.420 at our work session and over the course 00:38:16.420 --> 00:38:19.163 of the last couple of work sessions and now today, 00:38:20.550 --> 00:38:23.900 I think your updated memo is really trying 00:38:23.900 --> 00:38:27.640 to move in a direction that that does send 00:38:27.640 --> 00:38:30.500 the appropriate market signal and is more tailored 00:38:30.500 --> 00:38:34.050 to what, just setting that bar just a little bit higher 00:38:34.050 --> 00:38:37.360 so that we can drive that on to our batteries. 00:38:37.360 --> 00:38:39.190 My understanding is that most of the batteries 00:38:39.190 --> 00:38:41.730 that are in are ERCOT right now in the queue 00:38:41.730 --> 00:38:45.440 are one hour, one and a half hour. 00:38:45.440 --> 00:38:47.090 The duck curve that we're gonna be experiencing 00:38:47.090 --> 00:38:50.140 in the next one or two years, at least initially, 00:38:50.140 --> 00:38:51.910 maybe about two hours. 00:38:51.910 --> 00:38:56.910 So I'm taking all of those issues into consideration 00:38:58.010 --> 00:39:00.170 and certainly appreciate, 00:39:00.170 --> 00:39:03.180 I'm not as well versed on the storage ITC portion, 00:39:03.180 --> 00:39:05.250 but staying consistent with federal policy, 00:39:05.250 --> 00:39:08.860 I think makes sense so that you can drive that innovation 00:39:08.860 --> 00:39:10.140 and send the right price signal. 00:39:10.140 --> 00:39:11.760 And we're getting those technologies in there. 00:39:11.760 --> 00:39:16.400 But Chairman Lake, I see what you're saying as well 00:39:16.400 --> 00:39:18.343 on the operational end of it. 00:39:19.350 --> 00:39:21.450 My thought process has been, 00:39:21.450 --> 00:39:25.780 we're gonna get these resources, solar resources in Texas. 00:39:25.780 --> 00:39:28.620 Let's try to figure out a way to encourage them to show up 00:39:28.620 --> 00:39:31.990 with storage as best as we can. 00:39:31.990 --> 00:39:35.450 And I understand your comments about, 00:39:35.450 --> 00:39:39.030 well, let's just not like, you know, get everything 00:39:39.030 --> 00:39:41.050 sort of custom tailored to provide... 00:39:41.990 --> 00:39:44.890 To fit that need for the solar plus storage. 00:39:44.890 --> 00:39:46.080 I certainly understand that. 00:39:46.080 --> 00:39:48.280 My understanding my discussions with ERCOT 00:39:48.280 --> 00:39:52.620 is that they'll have a set of tools 00:39:52.620 --> 00:39:53.920 to address the duct curve, 00:39:55.080 --> 00:39:57.743 whether it be online generation resources, 00:39:59.050 --> 00:40:04.010 potentially some modification to non spin 00:40:04.010 --> 00:40:08.300 or just non spin period, and then eventually ECRs. 00:40:08.300 --> 00:40:13.300 So I think your updated memo moves it closer 00:40:14.828 --> 00:40:18.490 to the line of trying to drive that innovation 00:40:18.490 --> 00:40:22.330 and that drive that innovation to provide 00:40:22.330 --> 00:40:25.740 some of the reliability/operational benefits 00:40:25.740 --> 00:40:29.920 that we're looking for as we have a significant increase 00:40:29.920 --> 00:40:31.473 in solar in the next few years. 00:40:34.428 --> 00:40:38.207 I, myself looked at (indistinct), looked at the roles. 00:40:39.130 --> 00:40:43.760 And I think the fact that you're not stopping 00:40:43.760 --> 00:40:46.710 any resources from interconnecting, if they're ready to go. 00:40:49.460 --> 00:40:51.270 They won't be stopped from being interconnected. 00:40:51.270 --> 00:40:54.040 But if there is a situation where prioritization 00:40:54.040 --> 00:40:57.270 needs to take place, then ERCOT will prioritize 00:40:57.270 --> 00:41:02.270 based on what resources would be available 00:41:02.630 --> 00:41:07.010 to provide the dispatchable reliability need 00:41:07.010 --> 00:41:08.323 or service that we need. 00:41:09.700 --> 00:41:11.900 My understanding is that perhaps ERCOT 00:41:11.900 --> 00:41:14.410 already does some of this already. 00:41:14.410 --> 00:41:18.320 And if that is the case, I mean, I would love to hear 00:41:18.320 --> 00:41:19.960 from you know, if Woody, 00:41:19.960 --> 00:41:22.150 is this something y'all normally do already 00:41:22.150 --> 00:41:24.970 with respect to like when you have a mass amount 00:41:24.970 --> 00:41:29.700 of say projects, so that are looking to be interconnected 00:41:29.700 --> 00:41:32.140 and you have to do some kind of prioritization. 00:41:32.140 --> 00:41:34.093 Is this something you look at today? 00:41:40.890 --> 00:41:43.130 Woody Rickerson with ERCOT. 00:41:43.130 --> 00:41:44.980 So today through the screening process, 00:41:44.980 --> 00:41:48.900 we do not take into consideration multiple units 00:41:48.900 --> 00:41:50.490 connecting the same place. 00:41:50.490 --> 00:41:52.700 We know we don't tell the other people 00:41:52.700 --> 00:41:54.363 there's other competitors there. 00:41:56.971 --> 00:41:57.804 Is that what you were asking? 00:41:57.804 --> 00:42:00.860 Well, like If you already had projects ready to go, 00:42:00.860 --> 00:42:04.950 and do you do any prioritization right now? 00:42:04.950 --> 00:42:05.783 Oh, I'm sorry. 00:42:05.783 --> 00:42:08.120 So on the interconnection process. 00:42:08.120 --> 00:42:13.120 So a month ago we've made a change in the way we, 00:42:13.510 --> 00:42:17.160 within the protocol guidelines that we currently have, 00:42:17.160 --> 00:42:19.543 we moved dispatchable generator to the top. 00:42:20.470 --> 00:42:23.150 So if we had a dispatchable generator 00:42:23.150 --> 00:42:25.920 and a non dispatchable generator, 00:42:25.920 --> 00:42:28.120 our part of the interconnection process, 00:42:28.120 --> 00:42:31.610 we already moved that dispatchable one to the top 00:42:31.610 --> 00:42:33.040 while at the same time, 00:42:33.040 --> 00:42:37.163 maintaining all the required protocol. 00:42:38.090 --> 00:42:40.440 So everyone in the queue will still meet 00:42:40.440 --> 00:42:42.230 all the protocol timelines, 00:42:42.230 --> 00:42:46.483 but we're getting to prioritize the dispatchable unit. 00:42:48.740 --> 00:42:51.050 So in other words, Woody, 00:42:51.050 --> 00:42:54.380 nobody slides to the bottom or anything like that. 00:42:54.380 --> 00:42:58.242 It's a question of when you have five projects 00:42:58.242 --> 00:43:00.900 in a given area and you're trying to sort bandwidth 00:43:01.880 --> 00:43:04.450 and get the necessary studies complete, 00:43:04.450 --> 00:43:06.230 all those phases of studies, 00:43:06.230 --> 00:43:08.480 concurrent with transmission service providers 00:43:08.480 --> 00:43:11.040 who are doing their studies, 00:43:11.040 --> 00:43:12.940 their portions of the studies as well. 00:43:15.483 --> 00:43:17.370 This concept that you've heard from the dais 00:43:17.370 --> 00:43:20.640 simply provides some sort of order of merit 00:43:20.640 --> 00:43:23.290 in terms of prioritizing manpower 00:43:24.980 --> 00:43:28.010 when you have five projects. 00:43:28.010 --> 00:43:29.640 You take that dispatchable first 00:43:29.640 --> 00:43:32.210 and then you get to the intermittent. 00:43:32.210 --> 00:43:34.520 Yeah, we're not compromising any of the timelines 00:43:34.520 --> 00:43:38.690 that we're mandated to meet for anyone. 00:43:38.690 --> 00:43:41.300 Anyone that has a generation interconnection project, 00:43:41.300 --> 00:43:45.770 we're meeting all the protocol timelines for everyone. 00:43:45.770 --> 00:43:49.699 The only difference is now we have prioritized 00:43:49.699 --> 00:43:51.439 the dispatchable. 00:43:51.439 --> 00:43:52.637 And I think it's important to keep in mind-- 00:43:52.637 --> 00:43:54.850 And what was the discussion about that? 00:43:54.850 --> 00:43:58.850 I mean, it internally about why you did it 00:43:58.850 --> 00:44:00.030 about how you did it. 00:44:00.030 --> 00:44:02.090 Was there broad discussion amongst the stakeholders 00:44:02.090 --> 00:44:04.000 at ERCOT or was that... 00:44:04.000 --> 00:44:05.350 Can you fill me in on that? 00:44:08.030 --> 00:44:10.970 Well, I think the context there is that ERCOT 00:44:10.970 --> 00:44:13.313 is just one piece, one link in that chain. 00:44:14.750 --> 00:44:17.830 So if you think about this chain of events that has to occur 00:44:17.830 --> 00:44:20.209 for a generator to be interconnected, 00:44:20.209 --> 00:44:23.320 ERCOT has a piece here and a piece here and a piece here. 00:44:23.320 --> 00:44:24.993 So when we get to our piece, 00:44:26.010 --> 00:44:27.820 we're moving the dispatchable stuff to the top. 00:44:27.820 --> 00:44:30.850 Now there may be a way that we can decrease 00:44:30.850 --> 00:44:32.583 the length of the chain also, 00:44:33.610 --> 00:44:36.110 but for the guidelines that we currently have 00:44:36.110 --> 00:44:38.760 and the protocol requirements we currently have, 00:44:38.760 --> 00:44:40.930 we're just prioritizing the dispatchable. 00:44:40.930 --> 00:44:43.430 Now, all these other links in the chain 00:44:43.430 --> 00:44:45.830 that occur with TSPs, 00:44:45.830 --> 00:44:48.780 I mean, that's a lot of what the discussion has been about. 00:44:51.460 --> 00:44:52.900 I'm still a little unclear on it. 00:44:52.900 --> 00:44:57.287 I mean, it's my understanding that when a generator files 00:45:00.380 --> 00:45:02.050 in the interconnection cube, 00:45:02.050 --> 00:45:04.963 they go to the transmission provider first. 00:45:06.290 --> 00:45:08.283 They pay an application fee. 00:45:09.500 --> 00:45:12.360 And in fact, there's a process right there 00:45:12.360 --> 00:45:13.670 where they can expedite 00:45:14.829 --> 00:45:15.700 with many of the transmission providers 00:45:15.700 --> 00:45:17.930 where they can expedite using something 00:45:17.930 --> 00:45:20.563 called a discretionary spending account, 00:45:21.450 --> 00:45:25.490 where if they pre-fund the discretionary spending account, 00:45:25.490 --> 00:45:30.390 then the transmission service provider 00:45:30.390 --> 00:45:33.910 can not only do the studies, but they can also do 00:45:33.910 --> 00:45:36.020 engineering work perhaps on a substation 00:45:36.020 --> 00:45:38.313 or an interconnecting substation. 00:45:39.750 --> 00:45:43.120 And that is allowed by every resource. 00:45:43.120 --> 00:45:48.120 And if that's the case, do we even need to do this? 00:45:49.080 --> 00:45:53.480 Because, I mean, again, my view, 00:45:53.480 --> 00:45:56.293 I'm worried about those that are in the queue today, 00:45:57.620 --> 00:45:59.360 Queue in ERCOT is different from the queue 00:45:59.360 --> 00:46:04.360 in every other region because of the cost allocation 00:46:04.540 --> 00:46:07.660 component of transmission upgrades, 00:46:07.660 --> 00:46:10.630 which a lot easier here in ERCOT, obviously. 00:46:10.630 --> 00:46:15.630 But I'm worried about those projects that have site control, 00:46:18.270 --> 00:46:20.873 that have PPAs associated with their projects. 00:46:21.950 --> 00:46:24.313 They have contractual delivery timeframes, 00:46:26.971 --> 00:46:27.929 they have ordered equipment, 00:46:27.929 --> 00:46:29.990 all of these things that bind them. 00:46:29.990 --> 00:46:33.440 And most of those in this day and age are renewables. 00:46:33.440 --> 00:46:36.173 Sure, does the grandfathering clause address 00:46:36.173 --> 00:46:37.690 in (indistinct) address that concern? 00:46:37.690 --> 00:46:39.410 Well, I don't think we've explored that. 00:46:39.410 --> 00:46:41.630 And I mean, that's where I would say 00:46:42.660 --> 00:46:45.330 I would wanna have a deeper discussion about how we... 00:46:45.330 --> 00:46:48.070 Because this is substantial capital. 00:46:48.070 --> 00:46:51.130 This is not 45 grand or 50 grand. 00:46:51.130 --> 00:46:53.470 These are millions and millions and millions of dollars 00:46:53.470 --> 00:46:56.900 that are being tied up in these capital projects. 00:46:56.900 --> 00:47:01.900 And that if we just arbitrarily jigger them around, 00:47:02.060 --> 00:47:06.040 because we want to, that's not a good signal to the market. 00:47:06.040 --> 00:47:07.240 It doesn't incent. 00:47:07.240 --> 00:47:08.073 Sure. 00:47:08.073 --> 00:47:10.300 It does not insent dispatchable either 00:47:11.720 --> 00:47:13.880 because we could change the rules again 00:47:13.880 --> 00:47:16.110 and just go back and prioritize renewables 00:47:16.110 --> 00:47:17.520 and then dispatchables fall. 00:47:17.520 --> 00:47:20.540 So we have to be careful about what we do 00:47:20.540 --> 00:47:25.540 and that we need to make sure that it is fair. 00:47:26.410 --> 00:47:30.500 And those that are existing in the process... 00:47:30.500 --> 00:47:31.333 Absolutely. 00:47:31.333 --> 00:47:36.330 Have a method to stay in the process. 00:47:37.220 --> 00:47:39.140 I know also if I... 00:47:39.140 --> 00:47:40.600 Actually, I don't know, here in ERCOT, 00:47:40.600 --> 00:47:45.360 if I submitted an interconnection for 100 megawatt project 00:47:45.360 --> 00:47:48.030 and then have the ability to come back and add 00:47:50.865 --> 00:47:52.690 75 megawatt battery storage, 00:47:52.690 --> 00:47:54.830 I suspect I would fall out of the queue 00:47:54.830 --> 00:47:56.730 and I'd have to re enter the queue. 00:47:56.730 --> 00:47:57.730 Is that correct? 00:47:57.730 --> 00:48:00.443 Depending on where you were in the process, yes. 00:48:01.830 --> 00:48:04.000 Well, what technology you're talking about? 00:48:04.000 --> 00:48:05.200 Well, any change... 00:48:05.200 --> 00:48:06.833 If the change in a turbine type, 00:48:07.994 --> 00:48:10.080 it will require different studies, 00:48:10.080 --> 00:48:11.080 different stability studies-- 00:48:11.080 --> 00:48:12.983 Sure, absolutely. Different SSR study. 00:48:13.864 --> 00:48:17.840 So the purpose of the generation interconnection process 00:48:17.840 --> 00:48:21.460 is to safely and reliably interconnect new generation. 00:48:21.460 --> 00:48:22.293 Absolutely. 00:48:22.293 --> 00:48:24.110 I don't think there's anything in the process 00:48:24.110 --> 00:48:25.590 that isn't needed. 00:48:25.590 --> 00:48:27.760 We can't just go in and cut some fat out. 00:48:27.760 --> 00:48:28.860 There's not any fat there. 00:48:28.860 --> 00:48:30.630 Everything that's there is for purpose, 00:48:30.630 --> 00:48:34.434 whether it's the TSP doing it, whether it's ERCOT doing it 00:48:34.434 --> 00:48:35.570 or the review that you guys do, 00:48:35.570 --> 00:48:38.113 it's all there for a reason so that when we do interconnect 00:48:38.113 --> 00:48:40.487 that generation it's reliably interconnected 00:48:40.487 --> 00:48:42.733 and we don't have to worry about it 00:48:42.733 --> 00:48:43.566 causing a stability problem 00:48:43.566 --> 00:48:45.450 or an SSR problem or overload of line 00:48:45.450 --> 00:48:47.010 or something like that. 00:48:47.010 --> 00:48:48.480 So that's the... 00:48:48.480 --> 00:48:52.930 I think the background for all this is that all these things 00:48:52.930 --> 00:48:53.763 are needed. 00:48:53.763 --> 00:48:56.720 Maybe there's a way of lining them up 00:48:56.720 --> 00:48:59.980 so that we can decrease the interconnection time 00:48:59.980 --> 00:49:01.194 essentially. 00:49:01.194 --> 00:49:02.100 Maybe there's something we can do, 00:49:02.100 --> 00:49:03.840 but these engineering studies are needed 00:49:03.840 --> 00:49:05.740 and they do take time. 00:49:05.740 --> 00:49:08.190 And the timeframe now is about two years 00:49:08.190 --> 00:49:09.580 to go from start to finish. 00:49:09.580 --> 00:49:12.070 So if you were put in a year and a half ago 00:49:12.070 --> 00:49:14.973 and then we've rejiggered this, 00:49:15.890 --> 00:49:18.860 'cause you're just a wind farm with nothing else. 00:49:18.860 --> 00:49:20.610 I mean, that's where I'm concerned. 00:49:21.806 --> 00:49:24.940 And what I would say Commissioner McAdams 00:49:24.940 --> 00:49:29.550 is I would, if you wanna, I guess, 00:49:29.550 --> 00:49:30.500 let me just say it this way. 00:49:30.500 --> 00:49:31.640 I'd be happy to work with you 00:49:31.640 --> 00:49:33.730 on what these grandfathers are. 00:49:33.730 --> 00:49:35.930 I would be happy to have that discussion 00:49:35.930 --> 00:49:39.010 about real examples, 00:49:39.010 --> 00:49:41.610 not just talking with the transmission owners 00:49:41.610 --> 00:49:43.090 and what their interconnection process is, 00:49:43.090 --> 00:49:46.870 but understanding some of the real life PPAs associated 00:49:46.870 --> 00:49:50.090 with some of these farms with some of these projects, 00:49:50.090 --> 00:49:51.890 wind farms and solar farms and such. 00:49:53.680 --> 00:49:56.920 Yeah, no, I'm fully sensitive to that. 00:49:56.920 --> 00:50:01.480 And I'd welcome working through it, but I'll say this, 00:50:01.480 --> 00:50:05.340 there is 100,000 megawatts of solar in queue 00:50:06.290 --> 00:50:08.020 ballpark right now. 00:50:08.020 --> 00:50:11.920 And power is no different than any other market. 00:50:11.920 --> 00:50:13.090 The costs are no different. 00:50:13.090 --> 00:50:16.560 If I go out and buy a lot down the street from my house 00:50:16.560 --> 00:50:19.650 on a speculative basis and just hold the lot, 00:50:19.650 --> 00:50:24.370 and then I get into some type of weird permit process 00:50:24.370 --> 00:50:27.130 on like, but again, it's just a matter of fact case 00:50:27.130 --> 00:50:29.790 in point, I know I'll get a call from an HEB lobbyist. 00:50:29.790 --> 00:50:32.000 HEB in my neighborhood 00:50:32.890 --> 00:50:35.130 has been talking about putting in a grocery store 00:50:35.130 --> 00:50:36.460 for 10 years. 00:50:36.460 --> 00:50:39.430 And they've got preferential treatment from the developer 00:50:39.430 --> 00:50:42.340 or from the city in that neighbor 00:50:42.340 --> 00:50:45.240 to get that thing permitted and put in that grocery store. 00:50:47.137 --> 00:50:49.980 And they're holding this property, which is quite valuable 00:50:51.900 --> 00:50:53.480 to possibly put in that store. 00:50:53.480 --> 00:50:56.200 But at the end they might flip that to somebody else. 00:50:56.200 --> 00:50:58.330 So they put in the bare minimum of capital 00:50:58.330 --> 00:51:00.830 and they're holding their place in a permit line 00:51:00.830 --> 00:51:02.890 to get fast tracked through. 00:51:02.890 --> 00:51:05.120 And at the end of the day, 00:51:05.120 --> 00:51:07.170 we've gotta overcome those barriers. 00:51:07.170 --> 00:51:09.140 And I get they've got capital invested 00:51:09.140 --> 00:51:11.240 somewhere in their model. 00:51:11.240 --> 00:51:14.660 But for our view again, 00:51:14.660 --> 00:51:17.840 when we look at what only we can see, 00:51:17.840 --> 00:51:20.780 and again, I can't see what arrangements they've made 00:51:20.780 --> 00:51:24.480 so far in advance to hold that speculative position in line, 00:51:24.480 --> 00:51:29.241 but I can see when they collateralize with ERCOT 00:51:29.241 --> 00:51:33.320 and the TSPs and then they pay those interconnection amounts 00:51:33.320 --> 00:51:34.850 so that the studies can proceed 00:51:34.850 --> 00:51:36.550 and they're paying their way. 00:51:36.550 --> 00:51:39.820 We see that and we see that point in the line 00:51:39.820 --> 00:51:42.720 where they progress enough to where it's a financially 00:51:42.720 --> 00:51:44.510 and technically viable project. 00:51:44.510 --> 00:51:45.890 So that's, again, the-- 00:51:45.890 --> 00:51:47.170 Agreed. 00:51:47.170 --> 00:51:49.520 There are a lot of projects in the queue 00:51:49.520 --> 00:51:51.320 that do not wanna be studied 00:51:51.320 --> 00:51:53.230 in the interconnection process today. 00:51:53.230 --> 00:51:54.810 Yes, sir. 00:51:54.810 --> 00:51:58.763 Because there are companies that have limited resources. 00:51:59.840 --> 00:52:04.840 Their turbines may not come for 24 months or for four years. 00:52:06.220 --> 00:52:08.560 And you wouldn't want to spend your capital 00:52:08.560 --> 00:52:11.670 on the interconnection process today 00:52:11.670 --> 00:52:14.180 on a project that you know is so far off 00:52:14.180 --> 00:52:15.470 because of some of the examples, 00:52:15.470 --> 00:52:17.010 they may sell it to somebody else, 00:52:17.010 --> 00:52:18.460 let somebody else take the capital risk. 00:52:18.460 --> 00:52:19.990 So with that... 00:52:19.990 --> 00:52:22.570 But the question, you know, 00:52:22.570 --> 00:52:25.020 so that's not the issue that I'm trying to solve. 00:52:26.130 --> 00:52:28.900 I'm just trying to say that we have to figure out. 00:52:28.900 --> 00:52:31.320 Well, first of all, the problem that we're solving 00:52:31.320 --> 00:52:36.320 is not that I'm aware of that dispatchable plants 00:52:36.430 --> 00:52:39.160 aren't getting their interconnection studies. 00:52:39.160 --> 00:52:41.720 I have never heard a single company 00:52:41.720 --> 00:52:44.597 that has a dispatchable plant come in and say, 00:52:44.597 --> 00:52:47.357 "My interconnection cost is way too long. 00:52:47.357 --> 00:52:49.427 "I'm sorry, timeframe is way too long. 00:52:49.427 --> 00:52:51.027 "Please help me get through it." 00:52:52.210 --> 00:52:53.520 So, yes, sir. 00:52:53.520 --> 00:52:55.960 And I agree and that's why I don't believe 00:52:55.960 --> 00:52:57.770 this is gonna be an issue for those 00:52:57.770 --> 00:52:59.950 who have committed capital to buy equipment 00:52:59.950 --> 00:53:02.380 that are gonna deploy over the next two years. 00:53:02.380 --> 00:53:05.150 Nobody has told me that this is gonna be an issue. 00:53:05.150 --> 00:53:08.100 They worry about the signal that this sends 00:53:08.100 --> 00:53:09.470 to their financiers. 00:53:09.470 --> 00:53:11.520 And frankly, if their financiers have already given them 00:53:11.520 --> 00:53:13.230 money, they're kind of in bed with, 00:53:13.230 --> 00:53:15.230 I mean, they're committed. 00:53:15.230 --> 00:53:20.230 And so what I would say is that this doesn't put them 00:53:22.210 --> 00:53:25.190 to the bottom of any list, it does create an opportunity 00:53:25.190 --> 00:53:27.570 that if somebody goes out and gets a two hour 00:53:27.570 --> 00:53:32.570 megawatt battery, that a nameplate is 75% of the project 00:53:34.080 --> 00:53:36.020 that they're co locating with, 00:53:36.020 --> 00:53:38.200 they might get jumped in line 00:53:38.200 --> 00:53:41.800 in terms of that engineer focusing on that project next 00:53:41.800 --> 00:53:45.320 and getting it done, which is in the system's interest. 00:53:45.320 --> 00:53:46.710 I hear what you're saying, 00:53:46.710 --> 00:53:48.510 but I think a megawatt is a megawatt 00:53:50.810 --> 00:53:55.330 and that if you're telling people that they have to go buy 00:53:55.330 --> 00:53:57.890 put a 75 megawatt battery on a wind farm 00:53:57.890 --> 00:54:00.520 in order to get through the interconnection queue, 00:54:00.520 --> 00:54:03.480 this is a very massive transformation 00:54:03.480 --> 00:54:05.790 of what we're asking for in ERCOT. 00:54:05.790 --> 00:54:08.310 And economics may not work. 00:54:08.310 --> 00:54:10.260 But the federal government has said that a megawatt 00:54:10.260 --> 00:54:13.303 is not a megawatt on the basis that you're talking about. 00:54:14.517 --> 00:54:17.860 It funds it to a degree that it's different. 00:54:17.860 --> 00:54:20.073 It's fully funded by the federal government. 00:54:20.995 --> 00:54:21.863 You believe everything they say? 00:54:22.800 --> 00:54:25.590 Oh, no, I've seen it and I'm impressed. 00:54:25.590 --> 00:54:27.870 I'll say a megawatts is a megawatt, 00:54:27.870 --> 00:54:30.093 but every source of megawatt is not equal. 00:54:32.306 --> 00:54:37.306 And I think we all wanna welcome all generating resources 00:54:39.360 --> 00:54:44.360 to ERCOT given the strained situation we're in. 00:54:45.750 --> 00:54:50.470 But I will say that we've got that a firm dispatchable 00:54:50.470 --> 00:54:55.220 source of megawatts provides more value tomorrow 00:54:55.220 --> 00:54:59.553 than the 40th fourth out, 00:55:03.463 --> 00:55:07.670 you know, the 357th in plus one intermittent resource. 00:55:07.670 --> 00:55:11.880 We like all of them, but the value of dispatchability now, 00:55:11.880 --> 00:55:16.880 right now is greater than the value of an intermittent. 00:55:18.800 --> 00:55:23.083 Yeah, I think I agree with 80% of that. 00:55:24.290 --> 00:55:28.960 Not 20, but I think the price difference, 00:55:28.960 --> 00:55:33.330 you know, I think a great dispatchable resource 00:55:33.330 --> 00:55:38.330 at $12 gas is not as valuable as a zero cost wind resource. 00:55:38.528 --> 00:55:39.361 Sure. 00:55:39.361 --> 00:55:43.660 Sure, but when we've got 110, 120,000 megawatts 00:55:44.970 --> 00:55:49.190 of installed capacity, we're not short on generation, 00:55:49.190 --> 00:55:51.430 installed capacity generation in Texas. 00:55:51.430 --> 00:55:54.620 The problem is a third of that can vanish. 00:55:54.620 --> 00:55:55.453 I understand. 00:55:55.453 --> 00:55:57.630 Like last week and so that's the value of dispatchability. 00:55:57.630 --> 00:56:00.800 But I still go back to this question and that is, 00:56:00.800 --> 00:56:04.910 if there are opportunities for discretionary spending 00:56:04.910 --> 00:56:06.553 agreements already, 00:56:07.630 --> 00:56:10.330 can't we just encourage the dispatchable to go use those 00:56:10.330 --> 00:56:13.360 and get them done and go through the process, 00:56:13.360 --> 00:56:15.743 like they're already going through the process. 00:56:17.710 --> 00:56:20.180 They gotta come up with more money 00:56:21.420 --> 00:56:23.880 at a time when they're already on economic 00:56:23.880 --> 00:56:26.580 to get them to pay to play to fast track... 00:56:26.580 --> 00:56:28.710 I'm sorry, I'm dropping all kinds of things 00:56:28.710 --> 00:56:32.220 you shouldn't say, to get them fast track through a process 00:56:32.220 --> 00:56:33.330 at a time when the federal government 00:56:33.330 --> 00:56:35.250 is paying the other guy to play. 00:56:35.250 --> 00:56:37.414 And so anyway, it's convoluted. 00:56:37.414 --> 00:56:39.570 Everybody can use a discretionary spending agreement. 00:56:39.570 --> 00:56:42.550 Everybody can put money in to fast track the process 00:56:42.550 --> 00:56:44.450 and it doesn't take money out of your pocket, 00:56:44.450 --> 00:56:48.840 it accelerates right the time of what you're spending it 00:56:48.840 --> 00:56:51.910 because these are not dollars that you wouldn't have 00:56:51.910 --> 00:56:53.400 otherwise spent. 00:56:53.400 --> 00:56:56.810 It's fast-tracking engineering, contractor work, 00:56:56.810 --> 00:56:58.340 other things that are required 00:56:58.340 --> 00:56:59.890 for you to interconnect anyway. 00:57:00.880 --> 00:57:03.260 Apparently the economic signals aren't there 00:57:03.260 --> 00:57:04.610 'cause it's not being used. 00:57:05.758 --> 00:57:06.660 Well, I don't know if they're not being used. 00:57:06.660 --> 00:57:08.823 I haven't been told one way or the other. 00:57:13.008 --> 00:57:15.070 The one that goes to our market design, right. 00:57:15.070 --> 00:57:16.103 Partially, yeah. 00:57:17.320 --> 00:57:20.280 And so I think in the meantime, 00:57:20.280 --> 00:57:23.170 until that is decided upon and implemented, 00:57:23.170 --> 00:57:27.080 anything we can do to clear the way 00:57:27.080 --> 00:57:30.480 for dispatchable sources, 00:57:30.480 --> 00:57:33.610 I think is valuable enhancing our reliability. 00:57:33.610 --> 00:57:38.080 I am very, very, not 100% in agreement with you. 00:57:38.080 --> 00:57:43.044 I'll go 110% agreement with you on regulatory certainty. 00:57:43.044 --> 00:57:43.877 Yes. 00:57:45.120 --> 00:57:50.120 And ensuring that we do not pull the rug out 00:57:51.300 --> 00:57:54.490 from under folks who put real money to work. 00:57:54.490 --> 00:57:56.520 That's not the way this Commission should work, 00:57:56.520 --> 00:57:57.470 it's not the way ERCOT should work, 00:57:57.470 --> 00:57:59.260 it's not the way the state of Texas works. 00:57:59.260 --> 00:58:03.050 But I'm 110% with you on making sure 00:58:03.050 --> 00:58:04.130 that people that put money to work 00:58:04.130 --> 00:58:08.557 don't get cut off at the knees midstream. 00:58:13.649 --> 00:58:17.190 What if a solar farm that is number four in the queue 00:58:18.370 --> 00:58:20.120 is a 200 megawatt solar farm, 00:58:20.120 --> 00:58:23.533 and they don't have storage associated with it. 00:58:24.370 --> 00:58:27.020 Then the solar farm that does have storage 00:58:27.020 --> 00:58:30.330 associated with it, I'd rather have a number three 00:58:30.330 --> 00:58:31.250 in the queue. 00:58:31.250 --> 00:58:32.940 I might be in the wrong place on the system. 00:58:32.940 --> 00:58:34.620 I mean, that's (indistinct) 00:58:34.620 --> 00:58:35.670 Segment by segment. 00:58:36.650 --> 00:58:38.763 Well, I think my point is, 00:58:40.235 --> 00:58:43.047 I hope what I'm getting across is that 00:58:43.987 --> 00:58:46.920 there's not just one issue here, 00:58:46.920 --> 00:58:48.880 there are a lot of issues that I think 00:58:48.880 --> 00:58:50.610 if we wanna grandfather things, 00:58:50.610 --> 00:58:55.090 we ought to have a bigger discussion than just one memo 00:58:55.090 --> 00:58:59.370 and two discussions, is what I'm hoping. 00:58:59.370 --> 00:59:01.890 That would be my plea is that we could hear 00:59:01.890 --> 00:59:06.410 from all parties, have a bigger discussion about this 00:59:06.410 --> 00:59:09.940 and see if it doesn't mean a hill of beans, 00:59:09.940 --> 00:59:11.050 then we'll do it. 00:59:11.050 --> 00:59:15.163 And we need dispatchable resources, I know that. 00:59:16.280 --> 00:59:17.580 But I'm cognizant of a guy 00:59:17.580 --> 00:59:20.660 who's been in the interconnection queue before. 00:59:20.660 --> 00:59:25.650 And not fun sitting there deploying capital, 00:59:25.650 --> 00:59:27.320 never knowing when you're gonna get something 00:59:27.320 --> 00:59:29.020 and then to have something be modified 00:59:29.020 --> 00:59:33.070 to say that it's gonna be delayed even more, 00:59:33.070 --> 00:59:35.563 what happens then, your investors leave 00:59:35.563 --> 00:59:37.190 and your project goes away. 00:59:37.190 --> 00:59:38.950 And that's not a good cycle, 00:59:38.950 --> 00:59:43.950 it's not a good signal to send to the capital markets. 00:59:44.270 --> 00:59:45.387 Sure, but... 00:59:46.250 --> 00:59:50.183 Agreed and on the other side of that coin though, 00:59:53.110 --> 00:59:56.180 we need to have some signal or some mechanism 00:59:56.180 --> 00:59:59.680 so that the investor that's willing to associate 00:59:59.680 --> 01:00:03.290 their intermittent resource with storage and dispatchability 01:00:03.290 --> 01:00:07.080 is rewarded for that additional investment 01:00:08.060 --> 01:00:10.113 outside of crisis pricing. 01:00:12.040 --> 01:00:13.990 The question that I don't know is, 01:00:13.990 --> 01:00:17.810 could they say to a transmission service provider, 01:00:17.810 --> 01:00:20.467 look, "I'll fully fund my discretionary 01:00:20.467 --> 01:00:21.937 "spending account now." 01:00:22.900 --> 01:00:26.423 And then they go and do it under existing rules today. 01:00:27.400 --> 01:00:29.220 Very fair question. 01:00:29.220 --> 01:00:31.630 And per your earlier suggestion, 01:00:31.630 --> 01:00:36.140 would you to be willing to work on ironing out 01:00:36.140 --> 01:00:38.493 those details, but on the grandfather, 01:00:39.885 --> 01:00:43.260 grandfathering provision and clarifying 01:00:43.260 --> 01:00:46.300 what exactly that looks like? 01:00:46.300 --> 01:00:48.720 So we can ensure investment capital 01:00:48.720 --> 01:00:53.720 that has been deployed is, that it's mandate 01:00:53.820 --> 01:00:58.000 is respected and it's initial course 01:00:58.000 --> 01:01:00.210 that was charted can be implemented 01:01:00.210 --> 01:01:05.210 while also building off of Commissioner McAdams memo 01:01:06.210 --> 01:01:10.370 a framework to signal and incentivize 01:01:10.370 --> 01:01:13.914 and enable folks, investors who are willing 01:01:13.914 --> 01:01:16.563 to invest in dispatchable storage. 01:01:18.590 --> 01:01:21.010 Build on the principles he's laid out here 01:01:21.010 --> 01:01:22.453 to find a way to do that. 01:01:23.987 --> 01:01:25.750 These to be the interconnect here. 01:01:25.750 --> 01:01:27.760 If Commissioner McAdams is willing to do that, 01:01:27.760 --> 01:01:29.260 I would be glad to do that, absolutely. 01:01:29.260 --> 01:01:31.600 I am absolutely happy to do it 01:01:31.600 --> 01:01:33.663 and we'll continue to work on it. 01:01:34.530 --> 01:01:38.890 I will say there has to be a line in the sand 01:01:38.890 --> 01:01:43.890 and we have gigawatts of power 01:01:44.210 --> 01:01:47.580 that are bearing down on our system in the next two years 01:01:47.580 --> 01:01:50.970 that will have real reliability consequences. 01:01:50.970 --> 01:01:54.083 And this Commission again, 01:01:55.122 --> 01:01:56.260 and this is good, I enjoy this. 01:01:56.260 --> 01:01:57.820 I mean, this is good debate, good discussion 01:01:57.820 --> 01:01:59.360 and we will work out the details. 01:01:59.360 --> 01:02:02.450 And it'll be for the best of our resources 01:02:02.450 --> 01:02:03.290 one way or another. 01:02:03.290 --> 01:02:06.160 But, if there's no give, 01:02:06.160 --> 01:02:10.530 from the intermittent only community on this. 01:02:10.530 --> 01:02:12.980 If there has to be a fight, let it begin here. 01:02:12.980 --> 01:02:16.710 And because we've got to get some dispatchability 01:02:16.710 --> 01:02:18.560 co-located with these projects, 01:02:18.560 --> 01:02:20.590 and they must understand that, 01:02:20.590 --> 01:02:23.603 and their economics have to start working out. 01:02:24.650 --> 01:02:26.890 Because there's just too much anecdotal evidence 01:02:26.890 --> 01:02:29.043 to the contrary that it does. 01:02:29.990 --> 01:02:32.140 But I look forward to working with you on it. 01:02:32.140 --> 01:02:33.780 We'll find a good place. 01:02:33.780 --> 01:02:34.981 Thank you. 01:02:34.981 --> 01:02:35.950 Yes, sir. 01:02:35.950 --> 01:02:37.350 Alright, thank you, Woody. 01:02:38.520 --> 01:02:40.210 We also on this item, 01:02:40.210 --> 01:02:45.210 have a motion filed by staff regarding ERS. 01:02:50.230 --> 01:02:54.010 The motion is seeking good cause exception 01:02:54.010 --> 01:02:59.010 allowing ERCOT to deploy ERS before the EA declaration, 01:02:59.140 --> 01:03:02.190 rather than waiting until we are in the emergency situation 01:03:02.190 --> 01:03:05.863 to utilize the load resources that we have paid for. 01:03:07.640 --> 01:03:10.203 I'm sure staff is available for comments if needed, 01:03:11.880 --> 01:03:14.570 but at this point I'll open up for thoughts. 01:03:14.570 --> 01:03:17.160 And this is a topic we've discussed 01:03:17.160 --> 01:03:19.860 extensively in our various work sessions 01:03:19.860 --> 01:03:22.667 and open meetings that open up their thoughts 01:03:22.667 --> 01:03:23.593 and comments. 01:03:25.028 --> 01:03:25.861 (speakers talking over each other) 01:03:25.861 --> 01:03:26.694 It says a lot. 01:03:26.694 --> 01:03:27.527 Good thought. 01:03:28.410 --> 01:03:31.263 Well, first of all, thank you for laying that out. 01:03:32.713 --> 01:03:35.020 This is a concept and I have to give some credit 01:03:35.020 --> 01:03:35.910 to Commissioner McAdams. 01:03:35.910 --> 01:03:39.810 He's been putting ERS on the table for a few months now. 01:03:39.810 --> 01:03:42.743 And so in various memos, 01:03:43.630 --> 01:03:48.630 but after our market design workshop session that we had, 01:03:48.970 --> 01:03:51.380 not the last one, but the prior one, 01:03:51.380 --> 01:03:54.130 ERCOT highlighted that there is some (indistinct) 01:03:54.130 --> 01:03:56.610 with the emergency response service program 01:03:56.610 --> 01:03:57.560 that they run. 01:03:57.560 --> 01:04:02.270 And so as I was looking for additional near term 01:04:02.270 --> 01:04:05.490 and short term, mid-term and long-term solutions, 01:04:05.490 --> 01:04:09.170 I zoomed in on what can we do with the ERS right now 01:04:10.570 --> 01:04:13.900 to help add it as an additional tool to our toolbox 01:04:13.900 --> 01:04:16.090 or arsenal of actions that we can have 01:04:16.090 --> 01:04:19.023 in place and can take, rather, 01:04:20.265 --> 01:04:22.060 for this upcoming winter season. 01:04:22.060 --> 01:04:25.640 And so I had conversations with ERCOT, 01:04:25.640 --> 01:04:27.240 and really just for the public, 01:04:27.240 --> 01:04:28.460 just to explain once again, 01:04:28.460 --> 01:04:30.840 'cause I think this is important. 01:04:30.840 --> 01:04:34.160 ERCOT emergency response service program pays load 01:04:34.160 --> 01:04:38.070 and generation resources to reduce demand on the system 01:04:38.070 --> 01:04:40.210 during emergency events. 01:04:40.210 --> 01:04:43.260 So, in a continued effort to move away 01:04:43.260 --> 01:04:46.530 from a crisis based operation of the market, 01:04:46.530 --> 01:04:49.960 I had recommended or brought up as a point of discussion 01:04:49.960 --> 01:04:52.350 last week's work session that the Commission 01:04:52.350 --> 01:04:54.830 considered directing ERCOT to add more money 01:04:54.830 --> 01:04:57.820 to the upcoming winter contract period. 01:04:57.820 --> 01:05:00.463 which covers December, January and February. 01:05:01.387 --> 01:05:06.244 And also consider granting a good cause waiver, 01:05:06.244 --> 01:05:07.760 a good cause exception to our rules. 01:05:07.760 --> 01:05:09.610 To allow ERCOT, to deploy ERS 01:05:09.610 --> 01:05:12.880 earlier than an emergency event 01:05:12.880 --> 01:05:14.260 to help ensure reliability 01:05:14.260 --> 01:05:16.480 during this upcoming winter season. 01:05:16.480 --> 01:05:20.240 And so the feedback that we got from ERCOT, 01:05:20.240 --> 01:05:23.820 was that they would need to modify their RFP 01:05:23.820 --> 01:05:26.120 before November eighth, to: 01:05:26.120 --> 01:05:28.373 One, add more money and two, 01:05:30.607 --> 01:05:33.880 to allow to basically use ERS 01:05:33.880 --> 01:05:35.663 outside of emergency event earlier. 01:05:36.680 --> 01:05:39.910 So with that being said, 01:05:39.910 --> 01:05:42.070 and thank you staff for drafting 01:05:42.070 --> 01:05:43.933 the good cause exception order. 01:05:45.270 --> 01:05:47.350 Kenan Ogelman is here with ERCOT. 01:05:47.350 --> 01:05:50.260 And I think there's one sort of clarification 01:05:50.260 --> 01:05:55.260 that I would like to give ERCOT and Kenan 01:05:55.660 --> 01:05:57.363 about their deployment of ERS. 01:05:59.010 --> 01:05:59.960 I think there was a question, 01:05:59.960 --> 01:06:02.530 I think their good cause order says, 01:06:02.530 --> 01:06:04.760 may deploy before emergency event. 01:06:04.760 --> 01:06:08.240 And I think Kenan or ERCOT's intention 01:06:08.240 --> 01:06:13.240 would be to add will deploy to their RFP, 01:06:13.290 --> 01:06:15.930 the ERS contracts into the technical documents. 01:06:15.930 --> 01:06:18.920 And so, I wanna make sure we give that clarification now 01:06:18.920 --> 01:06:22.290 to Kenan and ERCOT so that they can use 01:06:23.889 --> 01:06:28.889 our desired approach in those three, I guess, documents. 01:06:30.770 --> 01:06:31.603 Yep. 01:06:31.603 --> 01:06:32.436 Well-put. 01:06:33.780 --> 01:06:34.670 What's your name? 01:06:34.670 --> 01:06:36.043 Kenan Ogelman with ERCOT, 01:06:39.330 --> 01:06:44.330 We don't, I mean, we think that the proposed order, 01:06:45.070 --> 01:06:47.570 or good cause exception would work, 01:06:47.570 --> 01:06:50.990 but I did wanna clarify with y'all 01:06:50.990 --> 01:06:52.690 how we would implement that. 01:06:52.690 --> 01:06:55.130 Which would be that we would implement 01:06:58.020 --> 01:07:02.430 deployment of ERS prior to EEA1 01:07:03.270 --> 01:07:07.170 in order to not enter EEA1 hopefully. 01:07:07.170 --> 01:07:11.980 That was my takeaway from what y'all had discussed. 01:07:11.980 --> 01:07:15.170 Nothing in the proposed good cause exception 01:07:15.170 --> 01:07:17.240 prohibits us from doing that. 01:07:17.240 --> 01:07:22.240 But, as we work some protocol changes through, 01:07:23.553 --> 01:07:27.293 I just wanted to make sure I read the room correctly. 01:07:28.990 --> 01:07:32.363 And then there was one other point I did wanna make. 01:07:33.320 --> 01:07:38.320 There was also discussion around in an increase in budget. 01:07:38.710 --> 01:07:43.710 And I'm curious if there might need to be some way 01:07:43.740 --> 01:07:47.750 to get the Commission's feedback 01:07:47.750 --> 01:07:50.950 on how much that increase should be. 01:07:50.950 --> 01:07:53.840 Because, if for example, 01:07:53.840 --> 01:07:57.860 I were to increase the winter budget by 20 million, 01:07:57.860 --> 01:08:00.360 but you only ultimately wanted to increase 01:08:00.360 --> 01:08:02.430 the overall budget by five. 01:08:02.430 --> 01:08:07.430 I would be shorting the summer and so forth. 01:08:07.490 --> 01:08:11.330 And then the last point that Woody will beat me up 01:08:12.466 --> 01:08:15.060 if I don't make this is, we can, I think, 01:08:15.060 --> 01:08:19.730 get everything done in a pretty judicious manner 01:08:19.730 --> 01:08:24.700 in terms of the RFP and issuing other binding documents. 01:08:24.700 --> 01:08:28.020 But there is an operator training element to this 01:08:28.020 --> 01:08:30.570 that we would also have to incorporate. 01:08:30.570 --> 01:08:33.870 And that might take a little bit of time. 01:08:33.870 --> 01:08:36.810 We can help you get that all laid out 01:08:36.810 --> 01:08:40.383 and moving down the tracks as expeditiously as possible. 01:08:41.670 --> 01:08:45.090 One high-level point of clarification I wanna make 01:08:45.090 --> 01:08:48.210 is that I think that while the good cause exception 01:08:48.210 --> 01:08:50.760 is the language is relatively broad, 01:08:50.760 --> 01:08:53.650 in no way do I think are we intending to adjust 01:08:53.650 --> 01:08:55.130 existing ERS contracts? 01:08:55.130 --> 01:08:57.110 We're gonna honor the existing contracts. 01:08:57.110 --> 01:08:58.330 That's correct. 01:08:58.330 --> 01:08:59.163 They're in place. 01:08:59.163 --> 01:09:01.693 This would be a going forward effort 01:09:03.650 --> 01:09:06.270 for the new contracts for the next season of ERS. 01:09:06.270 --> 01:09:08.560 So just want to clarify that we're not trying 01:09:08.560 --> 01:09:10.180 to retrade contracts. 01:09:10.180 --> 01:09:15.180 On your question of when it would be deployed 01:09:16.220 --> 01:09:21.220 before EEA is like what you said, 01:09:21.270 --> 01:09:22.180 I'd move that, 01:09:22.180 --> 01:09:23.860 I welcome the comments from others. 01:09:23.860 --> 01:09:25.500 I'd move that up even more 01:09:26.520 --> 01:09:31.520 because I certainly don't want to be asking Texans 01:09:31.810 --> 01:09:33.460 to turn down the lights in their homes 01:09:33.460 --> 01:09:36.360 and businesses and throttle down their lives 01:09:36.360 --> 01:09:38.790 before we've deployed the demand response 01:09:38.790 --> 01:09:40.283 that's already been paid for. 01:09:43.130 --> 01:09:45.820 That seems very straightforward to me, but... 01:09:45.820 --> 01:09:46.670 Absolutely 01:09:46.670 --> 01:09:48.380 To meet the non-negotiable policy 01:09:48.380 --> 01:09:49.530 that the Commissioners, 01:09:52.300 --> 01:09:54.240 has seemed to establish consensus on 01:09:54.240 --> 01:09:57.133 is EEA needs to be deployed before EEA1. 01:09:58.280 --> 01:09:59.113 ERS 01:09:59.113 --> 01:10:00.338 I'm sorry. 01:10:00.338 --> 01:10:02.070 ERS needs to be deployed before EEA1. 01:10:02.070 --> 01:10:03.083 What did I just say? 01:10:03.083 --> 01:10:04.166 I don't know, it's been a long day. 01:10:04.166 --> 01:10:04.999 It's before the EEA. 01:10:04.999 --> 01:10:06.530 No, before EEA1. 01:10:06.530 --> 01:10:10.400 Thus with the stated objective of preventing 01:10:10.400 --> 01:10:12.623 having to go into a conservation. 01:10:14.190 --> 01:10:19.190 Now, should ERCOT be granted the flexibility to do that 01:10:23.660 --> 01:10:26.840 and the MCL thing that which is kind of tied 01:10:26.840 --> 01:10:29.580 is still kind of moving pending the studies. 01:10:29.580 --> 01:10:32.960 So at this time I would suggest allowing them 01:10:32.960 --> 01:10:36.460 the flexibility to deploy before EEA1 01:10:36.460 --> 01:10:39.990 and use the technical and administrative 01:10:39.990 --> 01:10:43.626 discretion to deploy that, and just give them guidance. 01:10:43.626 --> 01:10:46.226 With the stated goal of do not go into conservation. 01:10:47.347 --> 01:10:48.535 Sure, absolutely. 01:10:48.535 --> 01:10:51.120 And that's what they're trying to solve for with ERS. 01:10:51.120 --> 01:10:53.480 I'm happy to defer operational decision-making 01:10:53.480 --> 01:10:56.640 to the operators on the ground, 01:10:56.640 --> 01:10:59.560 but in no uncertain terms do I wanna hear 01:10:59.560 --> 01:11:03.150 that we need to ask regular Texans to turn down their homes 01:11:03.150 --> 01:11:05.920 and businesses before we fully deployed that resource. 01:11:05.920 --> 01:11:07.840 Where are you, actually... 01:11:07.840 --> 01:11:11.973 What number PRC is deployed, I'll leave it to y'all, 01:11:14.050 --> 01:11:15.920 but I wanna make that clear. 01:11:15.920 --> 01:11:18.450 We need to use the demand response load resources 01:11:18.450 --> 01:11:20.820 we've already paid for before we start asking 01:11:20.820 --> 01:11:23.750 25 million people to change the way they run 01:11:23.750 --> 01:11:25.390 their daily lives. 01:11:25.390 --> 01:11:26.680 Does that work? 01:11:26.680 --> 01:11:27.520 Absolutely. Yes. 01:11:27.520 --> 01:11:28.353 Absolutely. 01:11:28.353 --> 01:11:31.700 And with respect to the amount, 01:11:31.700 --> 01:11:33.490 the additional amount that we would add 01:11:33.490 --> 01:11:36.680 to the winter contract period, if I may, 01:11:36.680 --> 01:11:39.920 I would suggest that maybe ERCOT come back 01:11:39.920 --> 01:11:41.970 to Commission staff with three options 01:11:42.960 --> 01:11:44.710 and dollar figures that we can assess 01:11:44.710 --> 01:11:47.400 and then work with ERCOT off line to determine 01:11:47.400 --> 01:11:49.750 what is that right balance of additional money 01:11:49.750 --> 01:11:52.030 we wanna add to the winter contract period 01:11:52.030 --> 01:11:56.760 to try to get more resources and or pay for the resources 01:11:56.760 --> 01:11:59.000 that we're gonna be asking to deploy a little bit earlier, 01:11:59.000 --> 01:12:00.850 that might cost a little bit more money 01:12:00.850 --> 01:12:03.160 and in balance with the rest of the contract periods 01:12:03.160 --> 01:12:04.920 in 2022, especially the summer. 01:12:04.920 --> 01:12:06.740 So I wanna strike that balance. 01:12:06.740 --> 01:12:09.550 And I think if you can bring back at least three options 01:12:09.550 --> 01:12:13.080 for staff to review, we can give you feedback offline 01:12:13.080 --> 01:12:16.005 as to what that appropriate amount would be. 01:12:16.005 --> 01:12:16.838 that appropriate amount would be. 01:12:16.838 --> 01:12:19.020 Or perhaps we could include it in the conversation 01:12:19.020 --> 01:12:20.863 for a work session next week. 01:12:21.980 --> 01:12:23.022 next week. 01:12:23.022 --> 01:12:23.855 Sure. 01:12:26.552 --> 01:12:27.901 I believe we can meet that as well. 01:12:27.901 --> 01:12:28.734 I think we can turn something around 01:12:28.734 --> 01:12:29.567 By next Thursday, okay. 01:12:29.567 --> 01:12:31.333 Yeah, sounds good. 01:12:33.420 --> 01:12:34.747 Yea, sounds good. 01:12:36.560 --> 01:12:39.270 All right, is there anything else, 01:12:39.270 --> 01:12:42.150 any other questions you need answered from us? 01:12:42.150 --> 01:12:45.152 No, I think I'm just wanted to... 01:12:45.152 --> 01:12:46.050 I didn't wanna take you by surprise 01:12:46.050 --> 01:12:51.050 when we were going to clearly in the RFP state 01:12:51.390 --> 01:12:54.990 that it was gonna happen at a PRC level 01:12:54.990 --> 01:12:56.653 in advance of the EEA1. 01:12:57.680 --> 01:13:00.290 That was definitely what my takeaway was, 01:13:00.290 --> 01:13:03.840 but just wanted to make that confirmed. 01:13:03.840 --> 01:13:04.673 Absolutely. 01:13:04.673 --> 01:13:09.530 And as always, we will continue to utilize all of the tools 01:13:11.040 --> 01:13:15.380 available to us, including a conservation notice, 01:13:15.380 --> 01:13:17.090 hopefully not, 01:13:17.090 --> 01:13:19.900 but it's this standard reminder that we'll use 01:13:19.900 --> 01:13:21.310 all tools available to us, 01:13:21.310 --> 01:13:23.330 ERS being one that we would prefer to use 01:13:23.330 --> 01:13:25.360 before conservation notice. 01:13:25.360 --> 01:13:26.193 Understood. 01:13:27.050 --> 01:13:30.670 One just question something to consider, 01:13:30.670 --> 01:13:34.040 given the fact that ERCOT is gonna insert 01:13:34.040 --> 01:13:37.700 that they will deploy ERS before EEA1 01:13:37.700 --> 01:13:41.330 in their RFP contracts for the winter period 01:13:41.330 --> 01:13:42.370 and technical documents. 01:13:42.370 --> 01:13:44.630 Is it makes sense to modify our order 01:13:44.630 --> 01:13:46.420 to change it from may to will. 01:13:51.800 --> 01:13:54.510 I don't know that it makes a difference. 01:13:54.510 --> 01:13:57.490 I'll defer to Commission council on... 01:13:59.037 --> 01:14:00.330 So I take our order off of this motion 01:14:00.330 --> 01:14:02.950 is simply waiving the requirement of the rule 01:14:02.950 --> 01:14:06.380 that requires you to wait until EEA1 has been declared. 01:14:06.380 --> 01:14:09.660 We're not giving you any further guidance, 01:14:09.660 --> 01:14:11.230 We're removing a restriction not providing direction. 01:14:11.230 --> 01:14:12.323 We are removing a restriction 01:14:12.323 --> 01:14:16.990 and that's the good cause waiver that this motion is. 01:14:16.990 --> 01:14:18.660 Which grants maximum flexibility. 01:14:18.660 --> 01:14:21.950 Yes, the direction you just given to ERCOT they've heard 01:14:21.950 --> 01:14:24.380 and it sounds like that's their intended plan 01:14:24.380 --> 01:14:25.213 moving forward. 01:14:25.213 --> 01:14:26.680 Okay, I just wanted to ask to see 01:14:26.680 --> 01:14:28.330 if there was any appetite for doing that 01:14:28.330 --> 01:14:29.163 and what the bounds were. 01:14:29.163 --> 01:14:29.996 worked. 01:14:31.360 --> 01:14:34.600 Commissioners, the language of staff's motion 01:14:34.600 --> 01:14:36.890 includes the word may specifically 01:14:36.890 --> 01:14:40.691 for the reason that you just discussed with Mr. Junae. 01:14:40.691 --> 01:14:44.410 that you just discussed with Mr. Journey. 01:14:44.410 --> 01:14:47.553 That we believe it would be your intention 01:14:47.553 --> 01:14:51.642 and expert discretion regarding when exactly to employ. 01:14:51.642 --> 01:14:53.142 exactly to employ. 01:14:54.921 --> 01:14:57.361 So you're removing the, excuse me, 01:14:57.361 --> 01:14:58.942 you're removing the restriction. 01:14:58.942 --> 01:14:59.828 It works for me, works for y'all. 01:14:59.828 --> 01:15:01.459 Yes. Great. 01:15:01.459 --> 01:15:02.292 Yes. 01:15:02.292 --> 01:15:03.507 In that case, the... 01:15:05.331 --> 01:15:06.914 In that case, the.. 01:15:08.788 --> 01:15:09.740 I will move to grant the good cause exception. 01:15:09.740 --> 01:15:11.240 Second. Second 01:15:12.630 --> 01:15:14.457 Two seconds, outstanding. 01:15:14.457 --> 01:15:15.290 (Laughing) 01:15:15.290 --> 01:15:16.777 All in favor. 01:15:16.777 --> 01:15:19.453 [Commissioners Together] Aye. 01:15:19.453 --> 01:15:22.320 None opposed, the motion passes. 01:15:22.320 --> 01:15:25.333 I don't have anything on item 25. 01:15:25.333 --> 01:15:26.166 Do y'all? 01:15:27.080 --> 01:15:30.333 No, but I did have something on 26, just a brief update. 01:15:32.650 --> 01:15:33.510 Tiny brief update. 01:15:33.510 --> 01:15:35.071 Lets go to 26 then. 01:15:35.071 --> 01:15:35.904 (Laughing) 01:15:35.904 --> 01:15:37.670 Oh, I'm sorry, did I do... 01:15:37.670 --> 01:15:38.510 Did I jump around? 01:15:38.510 --> 01:15:39.570 I'm sorry. 01:15:39.570 --> 01:15:42.100 We're all down moving the train down the trucks. 01:15:42.100 --> 01:15:42.933 Oh, I'm sorry. 01:15:42.933 --> 01:15:44.030 Yes, I skipped a few. 01:15:44.030 --> 01:15:45.486 Sorry. 01:15:45.486 --> 01:15:47.640 Okay, so a few open meetings ago, 01:15:47.640 --> 01:15:51.650 I brought up some MISO related matters, 01:15:51.650 --> 01:15:53.770 and that was that MISO's currently looking 01:15:53.770 --> 01:15:56.500 at long range transmission planning. 01:15:56.500 --> 01:15:58.370 And in that analysis, 01:15:58.370 --> 01:16:01.743 they are looking to have cost allocation, 01:16:02.730 --> 01:16:06.860 separate cost allocation for MISO North Central 01:16:06.860 --> 01:16:09.960 region and a MISO South region. 01:16:09.960 --> 01:16:12.030 So the cost allocation they're looking at right now 01:16:12.030 --> 01:16:15.050 is separate for the two pods, the two regions. 01:16:15.050 --> 01:16:19.090 But recently MISO has stated 01:16:19.090 --> 01:16:22.110 that there could be situations that would trigger 01:16:23.340 --> 01:16:27.270 footprint wide transmission cost allocation 01:16:27.270 --> 01:16:32.270 and with our Southeast Texas rate payers. 01:16:32.850 --> 01:16:36.350 And introduce, (indistinct) Texas service territory, 01:16:36.350 --> 01:16:39.570 or a tiny pod of that big MISO footprint. 01:16:39.570 --> 01:16:43.580 So to use a phrase that Commissioner McAdams likes to use, 01:16:43.580 --> 01:16:47.700 I started setting the table with MISO, 01:16:49.690 --> 01:16:54.650 and letting them know that sending them the message 01:16:54.650 --> 01:16:56.460 that Texas would be strongly opposed 01:16:56.460 --> 01:16:59.413 to the use of a MISO footprint wide posted stamp 01:16:59.413 --> 01:17:02.120 cost allocation for transmission. 01:17:02.120 --> 01:17:04.100 Texas will not pay for transmission build 01:17:04.100 --> 01:17:05.750 out in MISO North Central region, 01:17:05.750 --> 01:17:09.110 if Texas rate payers do not receive a direct benefit 01:17:09.110 --> 01:17:11.003 from that transmission build out. 01:17:12.810 --> 01:17:15.460 And so I think it would be a very high hurdle. 01:17:15.460 --> 01:17:17.690 And what I'm saying and what I mean by this 01:17:17.690 --> 01:17:20.260 is that, as I said, you know, 01:17:20.260 --> 01:17:23.210 very small swath of Texas is in MISO. 01:17:23.210 --> 01:17:25.330 And if MISO ultimately decides 01:17:25.330 --> 01:17:28.970 to integrate the entire footprint and use 01:17:30.985 --> 01:17:33.110 one cost allocation methodology, 01:17:33.110 --> 01:17:36.860 transmission, postage stamp costs allocation 01:17:36.860 --> 01:17:40.523 as is currently done in ERCOT for the entire footprint, 01:17:41.724 --> 01:17:43.410 that we're gonna have a high hurdle 01:17:43.410 --> 01:17:46.120 for Texas rate payers in Southeast Texas 01:17:46.120 --> 01:17:48.213 to be paying for transmission up north. 01:17:49.330 --> 01:17:52.150 So I just started setting the table. 01:17:52.150 --> 01:17:54.570 I know that some of our peer in the Southeast 01:17:54.570 --> 01:17:57.030 have said even stronger words. 01:17:57.030 --> 01:17:58.840 But, about... 01:17:58.840 --> 01:18:00.290 There are other folks who aren't happy about it either. 01:18:00.290 --> 01:18:02.433 Yes, like Louisiana and Mississippi. 01:18:03.418 --> 01:18:06.440 And so, I just wanna start kind of laying, 01:18:06.440 --> 01:18:09.540 I want, one, to notify y'all of kind of this issue 01:18:09.540 --> 01:18:12.310 that came up and you might've seen it in SBP2 as well. 01:18:12.310 --> 01:18:13.550 Commissioner McAdams, 01:18:13.550 --> 01:18:16.500 but just to notify you and to let you know 01:18:16.500 --> 01:18:20.370 that I'm being mindful of the Texas rate payers 01:18:20.370 --> 01:18:22.180 in Southeast Texas at this time. 01:18:22.180 --> 01:18:24.160 I'm taking them into consideration 01:18:24.160 --> 01:18:26.460 and keeping them in mind is if MISO 01:18:26.460 --> 01:18:28.930 starts moving in that direction. 01:18:28.930 --> 01:18:30.177 Yeah. 01:18:30.177 --> 01:18:34.010 And to echo Commissioner Cobos comments on MISO. 01:18:34.010 --> 01:18:39.010 SBP has the issues faced in both regions are very similar. 01:18:40.710 --> 01:18:44.390 The electoral dynamic on decision-making 01:18:44.390 --> 01:18:49.390 is somewhat less volatile in terms of making a decision 01:18:50.780 --> 01:18:51.670 on the topic. 01:18:51.670 --> 01:18:54.090 It's more entrenched at the moment, 01:18:54.090 --> 01:18:57.570 but it's certainly similar in terms of those Southern 01:18:57.570 --> 01:19:02.570 more load sensitive states versus the resource states 01:19:02.570 --> 01:19:03.720 in the Western regions. 01:19:06.698 --> 01:19:08.810 I appreciate you bringing that to our attention 01:19:08.810 --> 01:19:10.543 and certainly share your concern. 01:19:11.709 --> 01:19:13.020 Please keep us updated as that develops. 01:19:13.020 --> 01:19:16.170 And I suspect since we're talking 01:19:16.170 --> 01:19:19.310 about Southeast Texas and another ISO, 01:19:19.310 --> 01:19:20.820 I suspect Commissioner Glotfelty 01:19:20.820 --> 01:19:22.210 has got a few thoughts on that. 01:19:22.210 --> 01:19:27.210 Well, I appreciate the efforts in these other regions. 01:19:28.490 --> 01:19:30.837 We still represent those Texans as well. 01:19:30.837 --> 01:19:33.240 So I think it's important. 01:19:33.240 --> 01:19:35.240 To that end again, 01:19:35.240 --> 01:19:39.440 a few meetings ago when we discussed 01:19:39.440 --> 01:19:43.480 a transitioned to competition payment for energy. 01:19:43.480 --> 01:19:48.480 I had brought up that maybe we should have looked at, 01:19:50.300 --> 01:19:52.533 if there's a need for competition down there, 01:19:53.650 --> 01:19:56.310 we oughta hear from folks who want competition 01:19:56.310 --> 01:19:57.720 down there. 01:19:57.720 --> 01:19:59.050 So to that end, 01:19:59.050 --> 01:20:01.380 I just want to announce that we've opened 01:20:01.380 --> 01:20:05.580 a project number 52760 for interested stakeholders 01:20:05.580 --> 01:20:08.780 to file comments based on the discussion 01:20:08.780 --> 01:20:10.040 that we had October 7th 01:20:10.040 --> 01:20:13.030 relating to competition and entered the service territory, 01:20:13.030 --> 01:20:15.460 as well as all other non-ERCOT areas. 01:20:15.460 --> 01:20:20.220 So we'll have that docket opened and-- 01:20:20.220 --> 01:20:21.800 Except for the far west. 01:20:21.800 --> 01:20:23.920 Except for the far west, correct. 01:20:23.920 --> 01:20:27.570 And we'll be able to get input 01:20:27.570 --> 01:20:30.080 and help guide us as we look 01:20:31.310 --> 01:20:33.560 to see if there's is something we need to do. 01:20:36.220 --> 01:20:37.230 Commissioner, what was the thinking 01:20:37.230 --> 01:20:41.335 on leaving out the far west on that? 01:20:41.335 --> 01:20:43.840 What was the policy kind of a lining the sand on that? 01:20:45.580 --> 01:20:49.780 Well, I would put them all in there the far west. 01:20:54.690 --> 01:20:58.700 I dunno, Mr. Junae, what I agreed with you 01:20:58.700 --> 01:21:01.650 pretty quickly, but I didn't really think about it. 01:21:01.650 --> 01:21:04.531 I thought I was following directions, sir. 01:21:04.531 --> 01:21:05.980 (laughing) 01:21:05.980 --> 01:21:07.180 How about we say this? 01:21:08.650 --> 01:21:10.430 How about we redo this? 01:21:10.430 --> 01:21:11.510 In any of the regions 01:21:13.580 --> 01:21:14.750 let's have folks file, 01:21:14.750 --> 01:21:18.560 and if we end up getting many comments 01:21:18.560 --> 01:21:20.510 into specific areas 01:21:20.510 --> 01:21:23.240 we can bifurcate those into separate regions 01:21:23.240 --> 01:21:25.260 and have separate proceedings on those. 01:21:25.260 --> 01:21:27.930 But we could think about all of them. 01:21:27.930 --> 01:21:29.090 So thank you for bringing that up. 01:21:29.090 --> 01:21:30.050 Absolutely, sir. 01:21:30.050 --> 01:21:33.550 And so just to recap your vision for this proceeding 01:21:33.550 --> 01:21:38.350 is to simply act as a repository for public petition 01:21:39.590 --> 01:21:44.590 and interest, and to make their interests known 01:21:46.750 --> 01:21:49.210 that competition may be good for their region, 01:21:49.210 --> 01:21:50.980 but with no preordained... 01:21:50.980 --> 01:21:54.030 And again, just to clarify, we're not reinitiating 01:21:54.030 --> 01:21:56.470 with the proceeding like any studies or again, 01:21:56.470 --> 01:21:59.350 not another $200 million project to study integration 01:21:59.350 --> 01:22:00.683 or anything like that. 01:22:03.000 --> 01:22:03.980 To answer your question. 01:22:03.980 --> 01:22:07.600 I think the chairman on October 7th said it right, 01:22:07.600 --> 01:22:10.390 which is if you want it, we should hear from you. 01:22:10.390 --> 01:22:12.340 And this is a method to hear from them. 01:22:14.250 --> 01:22:15.740 And thank you for asking that question, 01:22:15.740 --> 01:22:16.573 Commissioner McAdams. 01:22:16.573 --> 01:22:17.880 That was gonna be my question 01:22:18.760 --> 01:22:21.183 just in process, what the project was about. 01:22:23.160 --> 01:22:28.160 Certainly we have four utilities in the edges of Texas 01:22:29.040 --> 01:22:33.580 that are thriving and serving important customers 01:22:33.580 --> 01:22:34.723 out there as well. 01:22:36.400 --> 01:22:39.730 The only thing I wanna say that, you know, 01:22:39.730 --> 01:22:41.380 and I think Commissioner McAdams' 01:22:42.339 --> 01:22:43.172 kind of clarifying questions 01:22:43.172 --> 01:22:45.220 might help alleviate those concerns out there 01:22:45.220 --> 01:22:48.110 with respect to what is the goal of this project. 01:22:48.110 --> 01:22:49.483 Are there any next steps? 01:22:50.580 --> 01:22:55.580 So we have the non-ERCOT utilities that come in here 01:22:55.930 --> 01:23:00.930 from time to time and file CCNs for generation plans 01:23:01.060 --> 01:23:02.513 and other infrastructure. 01:23:04.080 --> 01:23:07.460 I wanna be mindful and really stress. 01:23:07.460 --> 01:23:10.460 This is an opportunity for stakeholders out there 01:23:11.570 --> 01:23:12.730 to voice concerns. 01:23:12.730 --> 01:23:16.410 But I also am mindful of the investment community 01:23:16.410 --> 01:23:17.770 that may be hearing this, 01:23:17.770 --> 01:23:22.440 that is putting up investment dollars for big plants 01:23:22.440 --> 01:23:24.950 on the edges of Texas that are expensive. 01:23:24.950 --> 01:23:27.847 And they may be thinking, "Well, goodness, 01:23:27.847 --> 01:23:30.767 "is our investment gonna still hold 01:23:30.767 --> 01:23:32.757 "with a regulated rate of return and these 01:23:32.757 --> 01:23:34.187 "vertically integrated utilities? 01:23:34.187 --> 01:23:36.947 "Or will these utilities ultimately be put in ERCOT?" 01:23:39.453 --> 01:23:40.880 You know, it's survival of the fittest at that point. 01:23:40.880 --> 01:23:45.880 And so that's the only sort of cautionary footnote 01:23:47.000 --> 01:23:49.200 I wanna add on this is that, you know, 01:23:49.200 --> 01:23:51.190 we wanna make sure that those areas 01:23:52.250 --> 01:23:55.680 out in El Paso and Amarillo and, you know, 01:23:55.680 --> 01:23:57.450 Texarkana and Beaumont, 01:23:57.450 --> 01:24:01.200 that all those corners and rate payers 01:24:01.200 --> 01:24:05.630 in those edges of Texas still get reliable service, 01:24:05.630 --> 01:24:08.000 still get access to all the services and infrastructure 01:24:08.000 --> 01:24:09.730 these companies are providing. 01:24:09.730 --> 01:24:11.670 And I know that they're diligent 01:24:11.670 --> 01:24:13.970 in making sure all that happens. 01:24:13.970 --> 01:24:18.060 And I just don't want for us to send regulatory uncertainty, 01:24:18.060 --> 01:24:21.290 shockwaves that ultimately get in the way of financing 01:24:21.290 --> 01:24:24.490 some of these big infrastructure projects 01:24:24.490 --> 01:24:28.493 as a result of this forum. 01:24:29.360 --> 01:24:32.391 But that's just the only thing I wanted to add. 01:24:32.391 --> 01:24:33.224 An important consideration. 01:24:33.224 --> 01:24:34.940 And I'm sure Commissioner Glotfelty, 01:24:34.940 --> 01:24:37.690 like the rest of us, will welcome commentary from them. 01:24:38.880 --> 01:24:40.632 Those who are investing. 01:24:40.632 --> 01:24:41.715 Absolutely. 01:24:42.710 --> 01:24:44.840 I'm sure they won't be shy. 01:24:44.840 --> 01:24:45.673 I'm sure they won't. 01:24:45.673 --> 01:24:50.650 But I echo Commissioner Cobos' concerned there. 01:24:50.650 --> 01:24:52.820 And just from my perspective 01:24:52.820 --> 01:24:54.630 for that financial community out there 01:24:54.630 --> 01:24:59.263 who invests in our non-ERCOT areas of Texas. 01:25:00.440 --> 01:25:01.850 You still have a framework. 01:25:01.850 --> 01:25:04.530 You still have a system to invest in 01:25:04.530 --> 01:25:06.990 that provides reliable, essential service, 01:25:06.990 --> 01:25:10.060 and that's gonna be there in the future regardless. 01:25:10.060 --> 01:25:13.770 But again, that's why we capture this as a repository, 01:25:13.770 --> 01:25:15.870 just for public petition, 01:25:15.870 --> 01:25:20.260 in the interest of assessing the virtues of competition 01:25:20.260 --> 01:25:21.840 in those unique areas of Texas. 01:25:21.840 --> 01:25:24.880 And as I said before, and as you know, and we all do, 01:25:24.880 --> 01:25:27.530 the legislature has spoken to this several times 01:25:27.530 --> 01:25:29.910 over the past two decades 01:25:29.910 --> 01:25:32.070 and they certainly have a voice here. 01:25:32.070 --> 01:25:35.233 So before any letters start rolling in, 01:25:36.260 --> 01:25:37.250 we respect that. 01:25:37.250 --> 01:25:38.083 Well put. 01:25:39.100 --> 01:25:40.670 All right. 01:25:40.670 --> 01:25:44.060 That concludes business on item 26. 01:25:44.060 --> 01:25:47.670 I don't have anything on 27. 01:25:47.670 --> 01:25:49.190 That'll bring us to 28. 01:25:49.190 --> 01:25:51.500 Commissioner Glotfelty filed a memo on this docket. 01:25:51.500 --> 01:25:53.230 Would you lay that out for us? 01:25:53.230 --> 01:25:55.180 I'm sorry, I'm talking so much today. 01:25:56.091 --> 01:25:56.957 No, we're glad you-- 01:25:58.480 --> 01:26:00.130 I don't like talking this much. 01:26:01.490 --> 01:26:03.776 We can put a three minute limit on you. 01:26:03.776 --> 01:26:05.726 (laughing) 01:26:05.726 --> 01:26:06.710 That would be great. 01:26:06.710 --> 01:26:07.543 Steven. 01:26:09.930 --> 01:26:11.820 I think again, on October 7th, 01:26:11.820 --> 01:26:14.400 when Commissioner Cobos was talking about transmission, 01:26:14.400 --> 01:26:15.620 one of the issues that I brought up 01:26:15.620 --> 01:26:18.880 was the use of new technologies that are out there 01:26:18.880 --> 01:26:20.910 and have been utilized across the system, 01:26:20.910 --> 01:26:23.525 across the United States and across the world. 01:26:23.525 --> 01:26:24.358 (beeping) 01:26:24.358 --> 01:26:25.466 (laughing) 01:26:25.466 --> 01:26:26.782 Three seconds or three minutes? 01:26:26.782 --> 01:26:27.615 I'm sorry. 01:26:27.615 --> 01:26:29.303 Thank you, Commissioner Glotfelty. 01:26:29.303 --> 01:26:30.730 Well put. 01:26:30.730 --> 01:26:31.780 Do I hear a motion? 01:26:34.600 --> 01:26:37.350 These technologies dynamic line rating technologies 01:26:37.350 --> 01:26:39.510 are proven in the market. 01:26:39.510 --> 01:26:42.710 They're on many transmission lines around the state. 01:26:42.710 --> 01:26:47.097 What they do is instead of a static writing 01:26:48.770 --> 01:26:51.110 for a transmission line on throughput, 01:26:51.110 --> 01:26:53.280 how many megawatts can go through a line? 01:26:53.280 --> 01:26:57.580 They use components that are actually added to the system, 01:26:57.580 --> 01:27:00.580 which measure temperature, wind speed, 01:27:00.580 --> 01:27:05.300 other things that give a real-time value 01:27:05.300 --> 01:27:07.110 for the amount of megawatts 01:27:07.110 --> 01:27:09.700 that can be put through those lines. 01:27:09.700 --> 01:27:13.890 I know Encore and others in Texas do use it 01:27:13.890 --> 01:27:14.830 on some areas. 01:27:14.830 --> 01:27:19.830 And other transmission owners around the state use it less. 01:27:19.980 --> 01:27:24.980 And my point in this project is to really see, 01:27:25.370 --> 01:27:26.940 is there more need for this? 01:27:26.940 --> 01:27:29.710 Is there an opportunity to utilize this 01:27:29.710 --> 01:27:34.210 as a lower-cost way to get more megawatts to load centers? 01:27:34.210 --> 01:27:38.210 And it's not an expensive technology. 01:27:38.210 --> 01:27:39.920 It is a proven technology. 01:27:39.920 --> 01:27:41.730 So what I would suggest in the memo 01:27:41.730 --> 01:27:44.020 is that we direct staff to open a new project 01:27:45.020 --> 01:27:47.030 that deals with dynamic line writing, 01:27:47.030 --> 01:27:50.460 specifically as that technology and that we direct 01:27:50.460 --> 01:27:54.930 the TDUs in ERCOT to answer a series of questions 01:27:54.930 --> 01:27:58.150 about their use, not only the positives, 01:27:58.150 --> 01:28:00.560 but the negatives of these technologies as well. 01:28:00.560 --> 01:28:04.410 I think we need to have a fair understanding 01:28:04.410 --> 01:28:07.853 of if there are pros to this and if there are cons to this. 01:28:09.573 --> 01:28:12.050 But it is a technology that's utilized across the U.S. 01:28:12.050 --> 01:28:13.160 and across the world 01:28:13.160 --> 01:28:15.243 and could have some value here in ERCOT. 01:28:19.320 --> 01:28:20.373 A little more than three minutes. 01:28:20.373 --> 01:28:21.206 But that's okay. 01:28:21.206 --> 01:28:22.520 However, my three minutes. 01:28:24.070 --> 01:28:27.370 Nicely put, certainly, if we know anything, 01:28:27.370 --> 01:28:29.870 we know there's room for improvement in this realm 01:28:31.240 --> 01:28:35.253 and an opportunity to enhance the resources we've got. 01:28:36.120 --> 01:28:39.040 Certainly, support the notion of opening a project 01:28:39.040 --> 01:28:42.400 and directing that segment of our stakeholders 01:28:42.400 --> 01:28:44.033 to provide pros, cons, 01:28:45.250 --> 01:28:50.250 and any more specific questions you'd want, 01:28:51.000 --> 01:28:52.920 or any of us would wanna include. 01:28:52.920 --> 01:28:55.810 Yeah, I would say that in my... 01:28:55.810 --> 01:28:57.030 I've listed 10 questions, 01:28:57.030 --> 01:28:59.243 but I would surely be open to other questions 01:28:59.243 --> 01:29:01.420 that other Commissioners would have 01:29:01.420 --> 01:29:03.690 if we want to add other things to that, 01:29:03.690 --> 01:29:05.653 I'd be absolutely open to that. 01:29:07.774 --> 01:29:08.607 Thoughts and comments. 01:29:08.607 --> 01:29:09.820 Thank you for your leadership on this issue. 01:29:09.820 --> 01:29:11.680 Commissioner Glotfelty. 01:29:11.680 --> 01:29:14.920 I think your questions are very robust and holistic, 01:29:14.920 --> 01:29:16.550 and I thought they were great questions. 01:29:16.550 --> 01:29:18.033 So I don't have anything to add. 01:29:21.730 --> 01:29:24.960 Yeah and on that Commissioner, 01:29:24.960 --> 01:29:29.370 so given that this would be an enhancement 01:29:29.370 --> 01:29:33.603 to our transmission systems. 01:29:38.420 --> 01:29:41.530 Do you envision long-term and should a question 01:29:41.530 --> 01:29:46.520 be posed in this direction that evaluates it? 01:29:46.520 --> 01:29:49.293 Should there be a cost benefit? 01:29:50.440 --> 01:29:53.440 And they do this already, a cost-benefit test 01:29:53.440 --> 01:29:54.860 on those enhancements. 01:29:54.860 --> 01:29:57.310 Again, what value do you add? 01:29:57.310 --> 01:29:58.800 And for the system reliability, 01:29:58.800 --> 01:30:03.460 what kind of transmission level threat mitigation 01:30:04.600 --> 01:30:07.160 performances offset those costs? 01:30:07.160 --> 01:30:08.386 I would be happy to add a question about how would you see 01:30:08.386 --> 01:30:13.386 a cost-benefit analysis of this technology... 01:30:16.110 --> 01:30:21.110 Being incorporated into your infrastructure analysis? 01:30:22.290 --> 01:30:23.580 I think that would be great. 01:30:23.580 --> 01:30:25.653 Okay, I'd like to add that. 01:30:25.653 --> 01:30:26.486 Absolutely. 01:30:26.486 --> 01:30:27.319 That sounds good to me. 01:30:28.990 --> 01:30:30.580 Works for me. 01:30:30.580 --> 01:30:34.620 Do you want to provide a timeline for those responses? 01:30:34.620 --> 01:30:37.400 I'm just gonna get in front of this. 01:30:37.400 --> 01:30:38.360 Why don't we just... 01:30:38.360 --> 01:30:40.733 I mean, I think it should be... 01:30:40.733 --> 01:30:41.840 I mean, is there a normal timeline? 01:30:41.840 --> 01:30:42.803 60 days? 01:30:43.840 --> 01:30:46.823 We've got a lot going on, so I don't wanna burden. 01:30:48.770 --> 01:30:51.270 I mean, I was thinking of talking to Connie 01:30:51.270 --> 01:30:54.690 about finding out how best to distribute these questions. 01:30:54.690 --> 01:30:56.560 Who do we wanna target them to? 01:30:56.560 --> 01:30:58.680 I'm not seeing necessarily an order here, 01:30:58.680 --> 01:31:01.850 but maybe a bit more of like we did in workshops, 01:31:01.850 --> 01:31:03.963 or just proposing questions to parties. 01:31:05.330 --> 01:31:09.383 Typically that would be more of a 30 to 60 day timeline. 01:31:11.260 --> 01:31:12.093 Yes, I agree. 01:31:12.093 --> 01:31:15.150 And I think this discussion will go a long way 01:31:15.150 --> 01:31:18.860 towards figuring out who might be 01:31:20.010 --> 01:31:22.210 the best folks to respond to that. 01:31:22.210 --> 01:31:23.860 Who would be the most interested? 01:31:23.860 --> 01:31:25.870 And I think 60 days is fine. 01:31:25.870 --> 01:31:30.400 You know, again, we've got really big fish to fry early 01:31:30.400 --> 01:31:31.570 in November and December. 01:31:31.570 --> 01:31:35.680 So this is a longer-term issue that I think we can 01:31:35.680 --> 01:31:37.930 get to a better discussion launch next year. 01:31:37.930 --> 01:31:39.473 So 60 days would be great. 01:31:40.410 --> 01:31:42.340 All right, do you have everything you need? 01:31:42.340 --> 01:31:45.543 Or I guess we've taken instruction from the dais 01:31:45.543 --> 01:31:47.330 when we opened the project 01:31:47.330 --> 01:31:49.770 and consider the guidance from the dais 01:31:49.770 --> 01:31:52.280 of direction to our relevant stakeholders? 01:31:52.280 --> 01:31:53.832 Correct. 01:31:53.832 --> 01:31:55.020 And some further guidance about the question 01:31:55.020 --> 01:31:56.213 on benefit costs. 01:31:57.598 --> 01:31:58.623 Yeah, yeah (indistinct). Yes. 01:31:59.570 --> 01:32:00.790 Okay. 01:32:00.790 --> 01:32:03.260 Would you like to update your memo with that question? 01:32:03.260 --> 01:32:04.523 Filed under this project? 01:32:06.561 --> 01:32:08.011 There was another question. 01:32:10.510 --> 01:32:11.920 If we open up a project number, 01:32:11.920 --> 01:32:15.023 I would like this memo to be added to that project number. 01:32:18.832 --> 01:32:20.120 Is it appropriate for me to... 01:32:20.120 --> 01:32:21.320 Why don't I do that? 01:32:21.320 --> 01:32:24.721 I'll update the memo 01:32:24.721 --> 01:32:26.710 with Commissioner McAdam's question 01:32:26.710 --> 01:32:29.080 and re-circulated it. 01:32:29.080 --> 01:32:33.320 Do we have a docket number or a project number? 01:32:33.320 --> 01:32:35.290 We need to look to see whether we got something 01:32:35.290 --> 01:32:37.290 existent or we need to create another one. 01:32:37.290 --> 01:32:41.270 And then if this is sort of like, 01:32:41.270 --> 01:32:43.100 staff's gonna put out questions, 01:32:43.100 --> 01:32:44.730 I don't know that you need to redo your memo. 01:32:44.730 --> 01:32:47.263 We just need to perform the question. 01:32:48.390 --> 01:32:49.967 Can you work with staff to figure out... 01:32:49.967 --> 01:32:50.800 Absolutely. 01:32:50.800 --> 01:32:51.920 The best way to move forward with this 01:32:51.920 --> 01:32:55.130 and staff can update her individual offices separately? 01:32:55.130 --> 01:32:55.963 Yes. 01:32:57.238 --> 01:32:59.783 All right, there we go. 01:33:00.810 --> 01:33:04.630 I don't have anything on 29, 30, 31. 01:33:08.690 --> 01:33:11.780 Hearing no other topics on those items, 01:33:11.780 --> 01:33:14.433 that brings us to agenda item number 32. 01:33:16.210 --> 01:33:18.460 I think our executive director has an update. 01:33:21.050 --> 01:33:22.110 Thank you, Mr. Chairman, Commissioners 01:33:22.110 --> 01:33:25.343 for my two minutes today that I will take. 01:33:26.780 --> 01:33:27.613 It's not three. 01:33:27.613 --> 01:33:28.730 If you gave Commissioner Glotfelty three, 01:33:28.730 --> 01:33:31.319 I'll just take two, thank you, chairman. 01:33:31.319 --> 01:33:32.152 I appreciate the self muzzling. 01:33:32.152 --> 01:33:32.985 Absolutely. 01:33:32.985 --> 01:33:34.260 Yeah, restraint, thank you. 01:33:34.260 --> 01:33:36.520 Just a quick update on our continued work 01:33:36.520 --> 01:33:39.050 with the railroad Commission and the oil and gas 01:33:39.050 --> 01:33:40.750 and electric industries to ensure 01:33:41.896 --> 01:33:45.290 that everyone is prepared for this upcoming winter. 01:33:45.290 --> 01:33:47.070 At the request of Commissioner McAdams, 01:33:47.070 --> 01:33:49.370 we held a meeting last Wednesday 01:33:49.370 --> 01:33:52.160 up in the railroad Commission's offices 01:33:52.160 --> 01:33:55.290 with more than 70 members, representatives 01:33:55.290 --> 01:33:56.550 from the oil and gas industry, 01:33:56.550 --> 01:33:58.770 as well as the electric industry, railroad Commission staff, 01:33:58.770 --> 01:34:02.940 and our staff to lay out any issues that are still existing 01:34:02.940 --> 01:34:06.163 going into this winter that remain needing to be addressed. 01:34:07.170 --> 01:34:09.290 That meeting lasted roughly three hours. 01:34:09.290 --> 01:34:11.540 We had a very robust discussion. 01:34:11.540 --> 01:34:12.640 Coming out of that, 01:34:12.640 --> 01:34:15.370 we have I'd say a handful of action items 01:34:17.025 --> 01:34:19.375 that PUC staff sent to the railroad Commission. 01:34:20.290 --> 01:34:23.500 I'm meeting with railroad Commission, 01:34:23.500 --> 01:34:25.920 executive director Wei Wang tomorrow 01:34:25.920 --> 01:34:28.310 to go over that action item list with the goal 01:34:28.310 --> 01:34:31.970 of getting everything on that list completed by January one, 01:34:31.970 --> 01:34:34.210 to ensure that we have done everything we can 01:34:34.210 --> 01:34:36.090 to be prepared for this upcoming winter. 01:34:36.090 --> 01:34:38.410 And once that action item list is finalized, 01:34:38.410 --> 01:34:40.090 I've already talked to each of your chiefs of staff, 01:34:40.090 --> 01:34:42.540 will come by and brief you on those action items. 01:34:45.310 --> 01:34:46.510 Thank you, sir. 01:34:46.510 --> 01:34:51.510 Will, I know you've been carrying a heavy load on this one. 01:34:52.490 --> 01:34:56.180 It's hard to understate the importance of this issue 01:34:56.180 --> 01:34:57.520 heading into winter. 01:34:57.520 --> 01:34:58.600 Yes, sir. 01:34:58.600 --> 01:35:02.230 I can affirm what Thomas briefed you on. 01:35:02.230 --> 01:35:04.720 It was a robust discussion. 01:35:04.720 --> 01:35:06.203 It was collaborative. 01:35:07.130 --> 01:35:10.920 I would say that from the... 01:35:10.920 --> 01:35:15.920 The takeaway perspective is that the analysis and evaluation 01:35:16.930 --> 01:35:19.160 by our transmission service providers 01:35:19.160 --> 01:35:21.933 for the upcoming winter is absolutely essential. 01:35:22.990 --> 01:35:27.990 It is the guiding star by which both the Commission, 01:35:30.375 --> 01:35:31.208 the public utility Commission 01:35:31.208 --> 01:35:33.390 and railroad Commission's efforts 01:35:34.570 --> 01:35:37.773 are fully underway and designed to address. 01:35:39.170 --> 01:35:42.030 We're not there yet, but we're gonna get there. 01:35:42.030 --> 01:35:46.040 And I appreciate Thomas and staff's work on this. 01:35:46.040 --> 01:35:47.256 Thank you. 01:35:47.256 --> 01:35:49.650 And I would just add that the most of the discussion 01:35:49.650 --> 01:35:52.340 centered around different tiers of criticality 01:35:53.850 --> 01:35:56.750 for different facilities, communication plans, 01:35:56.750 --> 01:35:59.620 as well as language around force measure 01:35:59.620 --> 01:36:01.563 and from fuel contracting. 01:36:04.900 --> 01:36:06.250 All very, very important. 01:36:07.560 --> 01:36:08.393 Thank you, Thomas. 01:36:08.393 --> 01:36:11.520 And then the second item is some sad news 01:36:11.520 --> 01:36:12.990 for those who haven't heard, 01:36:12.990 --> 01:36:14.480 our communications director, 01:36:14.480 --> 01:36:18.050 Andrew Barlow will be leaving us next Friday. 01:36:18.050 --> 01:36:22.000 So I just wanted to publicly thank him for his service here, 01:36:22.000 --> 01:36:24.780 especially during the winter storm and thereafter. 01:36:24.780 --> 01:36:27.350 You know, we have a one-person communications team 01:36:27.350 --> 01:36:29.630 and the amount of work that he had to do, 01:36:29.630 --> 01:36:32.920 including the number of interviews he gave 01:36:32.920 --> 01:36:35.260 to different media outlets during that the week 01:36:35.260 --> 01:36:38.590 of Winter Storm Uri and after that, 01:36:38.590 --> 01:36:41.800 was just incredible and we're gonna miss him. 01:36:41.800 --> 01:36:43.500 And I wish him all the best. 01:36:43.500 --> 01:36:44.820 I know everyone on staff does. 01:36:44.820 --> 01:36:47.653 And it will be very difficult to replace him on staff. 01:36:50.390 --> 01:36:52.610 Very, very sorry to see you go. 01:36:52.610 --> 01:36:56.890 We wish you all the best in your future endeavors. 01:36:56.890 --> 01:37:00.300 And to echo Thomas's sentiment, 01:37:00.300 --> 01:37:04.250 it's incredible how much energy, talent, 01:37:04.250 --> 01:37:08.653 and fun can fit into a one-person communications team. 01:37:10.150 --> 01:37:12.100 And if you can find the interview of hidden 01:37:12.100 --> 01:37:14.733 giving us an interview in Spanish, it's gold. 01:37:17.070 --> 01:37:19.219 Is that one of the auction items for us? 01:37:19.219 --> 01:37:20.052 (laughter) 01:37:20.052 --> 01:37:23.320 We may have to augment and add that after he leaves. 01:37:23.320 --> 01:37:24.153 Yeah. 01:37:25.130 --> 01:37:27.370 Certainly bid on that. 01:37:27.370 --> 01:37:28.470 We'll miss you Barlow. 01:37:29.690 --> 01:37:30.523 Thank you. 01:37:30.523 --> 01:37:31.356 We sure are, yeah. 01:37:31.356 --> 01:37:33.510 I mean, I'll never forget joining this Commission 01:37:34.669 --> 01:37:38.030 almost of six months ago and spent a long six months. 01:37:38.030 --> 01:37:41.700 But Andrew was what was living this before that. 01:37:41.700 --> 01:37:44.750 And I think we're gonna get together years from now. 01:37:44.750 --> 01:37:46.990 It's like this PUC reunion about everybody 01:37:46.990 --> 01:37:50.040 who either lived through that event or came in afterwards. 01:37:50.040 --> 01:37:52.840 And Andrew, you're sure gonna be welcomed. 01:37:52.840 --> 01:37:55.210 And you did good service for the state. 01:37:55.210 --> 01:37:56.710 Thanks for everything you did. 01:37:57.680 --> 01:37:59.580 Thank you, Andrew, for your service. 01:38:03.210 --> 01:38:05.940 You barely even know him, you just got here. 01:38:05.940 --> 01:38:07.920 He took my picture though and it's on the website. 01:38:07.920 --> 01:38:09.329 So, thank you. 01:38:09.329 --> 01:38:10.263 That was a good one. 01:38:11.310 --> 01:38:13.910 Oh yes, before you leave, your last assignment 01:38:13.910 --> 01:38:15.600 is to put our pictures on the wall. 01:38:15.600 --> 01:38:16.433 Oh yeah. 01:38:19.048 --> 01:38:24.048 All right, that brings us to agenda item number 33. 01:38:24.230 --> 01:38:27.660 I know Ms. Corona has a few comments 01:38:27.660 --> 01:38:29.420 on customer service. 01:38:29.420 --> 01:38:31.420 Thank you, Commissioners. 01:38:31.420 --> 01:38:32.690 I know it's been a long day, 01:38:32.690 --> 01:38:35.910 but this is a very important topic that I wanna be sure 01:38:35.910 --> 01:38:37.363 to bring to your attention. 01:38:38.720 --> 01:38:41.840 I'd like to give you an update on customer complaints. 01:38:41.840 --> 01:38:45.670 As you might imagine, our complaint investigation workload 01:38:45.670 --> 01:38:48.640 since winter storm Uri is heavier than it's been 01:38:48.640 --> 01:38:50.040 in quite some time. 01:38:50.040 --> 01:38:53.620 As a point of reference, we passed our 2020 01:38:53.620 --> 01:38:55.803 total complaint number in August. 01:38:57.680 --> 01:39:01.020 We have a relatively small team of staff members 01:39:01.020 --> 01:39:04.210 that investigate and respond to each and every one 01:39:04.210 --> 01:39:06.870 of those complaints and that small team 01:39:06.870 --> 01:39:08.423 is doing a fantastic job. 01:39:09.680 --> 01:39:14.680 However, we do need some help from our regulated community 01:39:15.420 --> 01:39:18.260 so that our investigators can work as efficiently 01:39:18.260 --> 01:39:20.683 as possible to help those customers. 01:39:22.550 --> 01:39:24.620 In serving the investigators, 01:39:24.620 --> 01:39:28.313 we found several opportunities for improvement, 01:39:29.150 --> 01:39:31.003 and we found a couple gold stars. 01:39:32.370 --> 01:39:35.340 So when the regulated community 01:39:35.340 --> 01:39:37.410 is responding to customer complaints 01:39:37.410 --> 01:39:41.170 filed as a Commission, there are a few things 01:39:41.170 --> 01:39:44.230 that make a timely resolution for the customer 01:39:44.230 --> 01:39:45.903 particularly challenging. 01:39:46.890 --> 01:39:50.180 I'd like to give you and the folks in the audience 01:39:51.273 --> 01:39:52.673 and online some examples. 01:39:54.430 --> 01:39:57.160 The top three challenges for our investigators 01:39:57.160 --> 01:40:01.810 were late responses, late responses 01:40:01.810 --> 01:40:05.420 and late responses. 01:40:05.420 --> 01:40:09.340 Please, please respond on time. 01:40:09.340 --> 01:40:11.963 The investigators waiting, the customers' waiting. 01:40:13.630 --> 01:40:16.330 That one is followed up pretty quickly 01:40:16.330 --> 01:40:18.520 by not responding at all. 01:40:18.520 --> 01:40:22.970 And that will earn you a visit from Mr. English, 01:40:22.970 --> 01:40:24.370 our director of enforcement. 01:40:26.390 --> 01:40:28.483 Not a personal visit, but an email. 01:40:34.064 --> 01:40:37.710 He'll do real games, I'm sure. 01:40:37.710 --> 01:40:42.230 A couple of other things though were of note, 01:40:42.230 --> 01:40:44.883 missing or incomplete documentation. 01:40:45.860 --> 01:40:49.880 So this includes when improvisor 01:40:49.880 --> 01:40:54.470 sends us a generic template of correspondence 01:40:54.470 --> 01:40:58.697 that says, "Dear blank, here's what's happening 01:40:58.697 --> 01:40:59.960 "with your account." 01:40:59.960 --> 01:41:02.930 Now we want to see dear Mr. Gleason 01:41:02.930 --> 01:41:06.210 and the exact letter that the customer received. 01:41:06.210 --> 01:41:08.720 The generic template out of your files 01:41:08.720 --> 01:41:10.853 is not helpful in the investigation. 01:41:13.220 --> 01:41:15.160 Responding to only one issue 01:41:15.160 --> 01:41:16.940 when the customer actually sites 01:41:16.940 --> 01:41:19.550 multiple problems with their account. 01:41:19.550 --> 01:41:22.310 We'd like to get all of the issues rounded up 01:41:22.310 --> 01:41:25.513 and dealt with in one fell swoop. 01:41:28.892 --> 01:41:31.520 Here's something that you might not realize 01:41:31.520 --> 01:41:35.710 is a problem, but is with the way we process complaints, 01:41:35.710 --> 01:41:38.580 responding in the body of an email 01:41:38.580 --> 01:41:42.070 instead of an attachment that automatically is fed 01:41:42.070 --> 01:41:45.770 into our database causes problems and delays for us. 01:41:45.770 --> 01:41:48.640 Staff has to go pull that out of an email, 01:41:48.640 --> 01:41:52.500 put it in a document and then load it to the database. 01:41:52.500 --> 01:41:54.163 It's just extra step for them. 01:41:56.293 --> 01:42:01.293 And then the final one that causes us problems 01:42:02.260 --> 01:42:06.000 is when a provider gives our investigator 01:42:07.150 --> 01:42:09.290 general company contact information 01:42:09.290 --> 01:42:13.140 like a 1800 number, rather than providing 01:42:13.140 --> 01:42:16.090 a specific point of contact for our investigator 01:42:16.090 --> 01:42:18.607 to follow up with on a given complaint. 01:42:19.640 --> 01:42:22.400 So these problems are not specific 01:42:22.400 --> 01:42:25.393 to any particular industry, but apply across the board. 01:42:26.410 --> 01:42:28.680 I would say in general that the large providers 01:42:28.680 --> 01:42:29.563 do a good job. 01:42:31.000 --> 01:42:33.500 Many smaller companies that don't often have 01:42:33.500 --> 01:42:36.110 the occasion to interact with the Commission 01:42:36.110 --> 01:42:37.480 have more difficulties. 01:42:37.480 --> 01:42:39.683 They just need more practice. 01:42:40.570 --> 01:42:42.930 For that, I'd recommend that the associations 01:42:42.930 --> 01:42:45.420 that represent these smaller providers 01:42:45.420 --> 01:42:47.170 reach out to them periodically 01:42:47.170 --> 01:42:49.453 with reminders of best practices. 01:42:50.780 --> 01:42:53.640 I'd like to wrap up though with some good news 01:42:53.640 --> 01:42:56.483 and share a couple of tips for excellent responses. 01:42:57.320 --> 01:43:00.560 First, reaching out to the customer promptly 01:43:00.560 --> 01:43:03.523 after a complaint is received is a great way to start. 01:43:04.710 --> 01:43:08.900 And secondly, when responding to our investigators, 01:43:08.900 --> 01:43:13.100 the best responses address the issue or issues 01:43:13.100 --> 01:43:15.600 raised by the customer and also provide 01:43:15.600 --> 01:43:18.530 additional context about the customer's account 01:43:18.530 --> 01:43:20.950 so that the investigator can understand 01:43:20.950 --> 01:43:22.780 the full resolution and see it 01:43:22.780 --> 01:43:24.660 from the customer's perspective, 01:43:24.660 --> 01:43:27.230 everything that's happening with their account. 01:43:27.230 --> 01:43:29.230 So thank you for your time. 01:43:29.230 --> 01:43:32.330 We will be reaching out to the regulated community 01:43:32.330 --> 01:43:36.320 and providing them with some of these tips, 01:43:36.320 --> 01:43:38.770 but I wanted to bring you all up-to-date as well. 01:43:40.503 --> 01:43:41.435 Thank you, Connie. 01:43:41.435 --> 01:43:43.760 I think it goes without saying that you and our staff 01:43:43.760 --> 01:43:46.320 have the full support of this Commission. 01:43:46.320 --> 01:43:50.970 A number of the failures that you mentioned 01:43:50.970 --> 01:43:54.230 are I think would categorize a good chunk of those 01:43:54.230 --> 01:43:56.800 as completely unacceptable, 01:43:56.800 --> 01:44:00.160 and a few of those as dramatically need improvement, 01:44:00.160 --> 01:44:02.860 but the emphasis on completely unacceptable 01:44:03.910 --> 01:44:06.783 is not something that I think any of us wanna tolerate. 01:44:07.910 --> 01:44:08.743 Thank you for the update. 01:44:08.743 --> 01:44:11.070 Yeah and Connie, I think it's safe to say 01:44:11.070 --> 01:44:13.330 from all of our perspectives, the competitive system 01:44:13.330 --> 01:44:15.610 is predicated upon our retail community 01:44:15.610 --> 01:44:18.350 and our market participants doing the right thing 01:44:18.350 --> 01:44:19.420 as a default setting. 01:44:19.420 --> 01:44:21.780 So all of the stipulations you laid out 01:44:21.780 --> 01:44:25.950 in terms of our complaint resolution system, 01:44:25.950 --> 01:44:28.090 that's predicated around them doing the right thing 01:44:28.090 --> 01:44:29.970 and complying in the right way. 01:44:29.970 --> 01:44:32.900 So this Commission is dedicated 01:44:32.900 --> 01:44:34.850 to keeping the competitive marketplace healthy, 01:44:34.850 --> 01:44:36.650 but that means our marketplace 01:44:36.650 --> 01:44:38.220 has to do the right thing 01:44:38.220 --> 01:44:40.030 and serve the consumer as well. 01:44:40.030 --> 01:44:43.500 So please know that you have our full support. 01:44:43.500 --> 01:44:45.070 Thank you for support Commissioners. 01:44:45.070 --> 01:44:47.610 And if any member of the regulated community 01:44:47.610 --> 01:44:51.040 has a question about how to respond 01:44:51.040 --> 01:44:53.230 or the best way to respond to a complaint, 01:44:53.230 --> 01:44:55.760 they can reach out to their assigned investigator 01:44:55.760 --> 01:44:58.450 or directly to our customer protection director, 01:44:58.450 --> 01:44:59.303 Chris Burch. 01:45:00.730 --> 01:45:01.920 Thank you for this update, Connie. 01:45:01.920 --> 01:45:04.400 And I just wanna echo the chairman's comments 01:45:04.400 --> 01:45:06.690 and Commissioner McAdams' comments. 01:45:06.690 --> 01:45:09.760 It is critically important for these companies 01:45:09.760 --> 01:45:13.090 to serve the customers and to be responsive. 01:45:13.090 --> 01:45:16.670 These customers are waiting to resolve their issues. 01:45:16.670 --> 01:45:20.750 And it's unacceptable that they're just kind of left 01:45:20.750 --> 01:45:23.370 to wonder when their complaints and resolutions 01:45:23.370 --> 01:45:26.530 and investigations will come to completion. 01:45:26.530 --> 01:45:29.280 So like my Commissioner McAdams has just said, 01:45:29.280 --> 01:45:33.600 we want a healthy, competitive retail electricity market. 01:45:33.600 --> 01:45:35.680 But a good component of that 01:45:35.680 --> 01:45:40.680 is to ensure effective service for the consumers. 01:45:40.820 --> 01:45:42.380 Thank you. 01:45:42.380 --> 01:45:43.213 Well put. 01:45:44.760 --> 01:45:47.240 All right, that brings us to item 34. 01:45:47.240 --> 01:45:49.730 I don't have anything on this item. 01:45:49.730 --> 01:45:51.210 Mr. Glotfelty, any thoughts? 01:45:51.210 --> 01:45:53.450 Just one more thing, sorry y'all. 01:45:53.450 --> 01:45:54.490 Three minutes. 01:45:54.490 --> 01:45:56.163 No, less than that. 01:45:57.410 --> 01:45:58.740 This deals with cybersecurity, 01:45:58.740 --> 01:46:03.610 obviously it's issue that every utility is dealing with, 01:46:03.610 --> 01:46:06.210 every generator, every participant ERCOT deals with. 01:46:07.780 --> 01:46:11.750 I just wanted to make the reminder or the encouragement 01:46:12.793 --> 01:46:17.793 that NERC is having one of their major cybersecurity events 01:46:19.860 --> 01:46:21.520 that's coming up called GridEx. 01:46:21.520 --> 01:46:23.140 It's November 16th and 17th. 01:46:24.290 --> 01:46:27.850 It is a distributed play exercise. 01:46:27.850 --> 01:46:32.120 And I think it is valuable for all of our utilities 01:46:32.120 --> 01:46:36.060 to participate in as many exercises as they can. 01:46:36.060 --> 01:46:38.923 And that the more we learn about these, 01:46:39.780 --> 01:46:43.403 not only cyber attacks, but physical attacks, 01:46:44.820 --> 01:46:47.350 we will be prepared if something, God forbid, 01:46:47.350 --> 01:46:48.840 ever does happen to the ERCOT system. 01:46:48.840 --> 01:46:50.313 So I just wanna bring this up 01:46:50.313 --> 01:46:52.170 that we encourage everybody to participate 01:46:52.170 --> 01:46:53.440 if they can. 01:46:53.440 --> 01:46:56.293 Absolutely, I'll second that. 01:46:57.710 --> 01:46:59.170 Cyber security is something 01:46:59.170 --> 01:47:01.290 that is an ever expanding threat 01:47:01.290 --> 01:47:04.563 that requires constant diligence. 01:47:05.860 --> 01:47:07.810 Thank you for highlighting that for us. 01:47:09.940 --> 01:47:13.100 All right, it's 3:09 p.m. 01:47:13.100 --> 01:47:14.570 There being no further business to come 01:47:14.570 --> 01:47:15.720 before the Commission, 01:47:15.720 --> 01:47:18.100 this meeting of the Public Utility Commission of Texas 01:47:18.100 --> 01:47:19.793 is hereby adjourned.