WEBVTT 00:00:08.339 --> 00:00:12.960 morning everybody. 00:00:16.140 --> 00:00:18.059 Good morning, everybody. 00:00:22.140 --> 00:00:26.550 Thank you for coming to today's informal workshop on 00:00:26.559 --> 00:00:28.989 the implementation of the emergency operations plan 00:00:28.989 --> 00:00:32.700 rule, I'm very happy to see so many people wearing 00:00:32.700 --> 00:00:37.560 blue jeans today. Congratulations. Thank you. Mm hmm 00:00:38.140 --> 00:00:41.409 I do want to let you know that this is being live 00:00:41.420 --> 00:00:46.310 broadcast on texas admin. So, um when you do have questions 00:00:46.310 --> 00:00:49.979 or comments, please come up to the bench here, grab 00:00:49.979 --> 00:00:54.189 a microphone, introduce yourself and the company or 00:00:54.189 --> 00:00:59.039 party that you're representing and um that way everybody 00:00:59.049 --> 00:01:02.100 who's playing from home will know what's going on here 00:01:02.179 --> 00:01:06.750 So thank you. Um, it's gonna be a very informal meeting 00:01:06.750 --> 00:01:09.260 today. What we're gonna do is we're gonna go through 00:01:09.260 --> 00:01:12.140 at a very, very, very high level introduce each subsection 00:01:12.140 --> 00:01:17.500 of the rule. Um, Mackenzie, um who's sitting here with 00:01:17.500 --> 00:01:20.840 me, we'll read through some of the pre filed questions 00:01:20.840 --> 00:01:23.519 that we got. Um we'll try to answer those and then 00:01:23.519 --> 00:01:27.280 after that we'll open it up for any questions or comments 00:01:27.450 --> 00:01:31.010 Well, questions really um, on that subsection and then 00:01:31.019 --> 00:01:32.969 once we're done with that, we'll move on to the next 00:01:32.969 --> 00:01:36.170 one. And um, I neglected to introduce myself before 00:01:36.170 --> 00:01:39.140 we got started. So I apologize for that. I am barksdale 00:01:39.140 --> 00:01:43.359 english and um let's have some fun. 00:01:45.340 --> 00:01:49.129 So we're gonna start with subsection a, the application 00:01:49.129 --> 00:01:53.019 section in this outlines to whom this rule applies 00:01:53.409 --> 00:01:57.049 Were there any pre filed questions on and any questions 00:01:57.060 --> 00:01:58.370 about subsection A 00:02:02.340 --> 00:02:05.959 excellent Cps is always late. 00:02:09.539 --> 00:02:13.889 Subsection B in here. We define some specific terms 00:02:13.889 --> 00:02:18.680 that apply to this rule? Um notably we have definitions 00:02:18.689 --> 00:02:22.919 of emergency hazard and threat in here. Do we have 00:02:22.919 --> 00:02:26.009 any questions about this Mackenzie? Any questions from 00:02:26.009 --> 00:02:26.360 the group? 00:02:29.039 --> 00:02:29.550 Cool. 00:02:31.639 --> 00:02:35.939 Moving on to subsection C. This is the filing requirements 00:02:36.240 --> 00:02:40.639 It lays out Who has to file what and when and it's 00:02:40.830 --> 00:02:43.699 staggered into two different sections, one for the 00:02:43.699 --> 00:02:47.199 implementation year. So the April 15 filing And then 00:02:47.199 --> 00:02:51.250 after calendar year 2022, what happens going forward 00:02:52.240 --> 00:02:55.699 Any questions about subsection C. Mackenzie? 00:02:59.039 --> 00:03:04.780 Um So I think one common question that we received 00:03:04.789 --> 00:03:08.159 um was about where the GOP filing should be submitted 00:03:08.740 --> 00:03:12.610 Um There is a current number that has historically 00:03:12.610 --> 00:03:15.889 been used for these filings. Um We will be opening 00:03:15.889 --> 00:03:24.379 a new project. Right? Um and so the filings April 15 00:03:24.389 --> 00:03:28.819 and going forward in future years will be under that 00:03:28.819 --> 00:03:30.669 new docket 00:03:33.539 --> 00:03:36.669 and that will be for what is filed at the puc, which 00:03:36.680 --> 00:03:40.939 is again the executive summary as outlined in the rule 00:03:40.939 --> 00:03:44.159 and then also the redacted copy 00:03:47.219 --> 00:03:50.129 any other pre filed questions subsection C. 00:03:51.840 --> 00:03:56.969 Then there is one um this is kind of general for if 00:03:56.969 --> 00:04:03.270 we have any templates or um asking for any specifics 00:04:03.280 --> 00:04:07.659 about what should be included. Um And so although we're 00:04:07.659 --> 00:04:09.889 talking about subsection C, I think this will apply 00:04:09.889 --> 00:04:13.039 to some of the questions perhaps throughout the rule 00:04:13.050 --> 00:04:19.149 which is um we're not prescribing um any particular 00:04:19.160 --> 00:04:25.829 form format or contents that should be decided based 00:04:25.829 --> 00:04:29.600 on your particular needs. Um and the uniqueness of 00:04:29.600 --> 00:04:35.110 your entities. So um we can discuss that more if there 00:04:35.110 --> 00:04:38.670 are specific questions as we go through the rule. Um 00:04:38.680 --> 00:04:42.560 But there were questions regarding that in filing. 00:04:43.139 --> 00:04:43.860 Um 00:04:45.439 --> 00:04:49.800 and then I think there were other questions regarding 00:04:49.800 --> 00:04:54.259 timelines with filing at the puc and then filing the 00:04:54.269 --> 00:04:58.410 full unredacted versions at ERCOT. Um Should that be 00:04:58.410 --> 00:05:01.180 done simultaneously? Should want to be done before 00:05:01.180 --> 00:05:05.699 or after? Um I think the idea is they should be those 00:05:05.699 --> 00:05:10.759 steps should be completed around the same time um That 00:05:11.639 --> 00:05:15.149 I guess concurrently shortly around the same time would 00:05:15.149 --> 00:05:17.980 be the timeline for that. There is not a requirement 00:05:17.980 --> 00:05:22.759 to file at ERCOT first and then the pc or vice versa 00:05:23.139 --> 00:05:31.170 Um So simultaneous filing um And then there were questions 00:05:31.170 --> 00:05:36.160 again. Now filing at ERCOT will segway here um look 00:05:36.170 --> 00:05:41.399 out. There will be a ERCOT notice um from ERCOT detailing 00:05:41.399 --> 00:05:45.850 how they would like these GOP s filed. Um And there 00:05:45.860 --> 00:05:48.300 may be some differences especially for those entities 00:05:48.300 --> 00:05:52.560 already filing E. O. P. S. Um under ERCOT protocols 00:05:54.139 --> 00:05:56.410 and they will post that information on their website 00:05:56.410 --> 00:05:59.199 as well. In addition to the ERCOT notice um for future 00:05:59.199 --> 00:06:05.360 reference um And then lastly on this for the pre filed 00:06:05.360 --> 00:06:08.750 questions and then we'll get to um those here in the 00:06:08.750 --> 00:06:13.050 room any additional questions um about making an unredacted 00:06:13.050 --> 00:06:17.040 E. O. P. Copy available to commission staff on request 00:06:17.050 --> 00:06:22.600 um that there will be notice provided to the entity 00:06:22.610 --> 00:06:29.709 and um it will be for physical viewing um you know 00:06:29.720 --> 00:06:33.560 likely here in Austin but those details will be communicated 00:06:34.139 --> 00:06:37.410 um with entities as we go through this process. 00:06:39.040 --> 00:06:39.519 Thank you. 00:06:44.339 --> 00:06:47.709 Hey, thanks. Can you hear me? Okay? Good morning. Thanks 00:06:47.709 --> 00:06:51.769 for doing this. Um really appreciate y'all taking time 00:06:51.769 --> 00:06:54.939 to kind of help provide guidance on the this important 00:06:54.939 --> 00:06:58.339 rule. I'm Julia harvey with texas Electric Cooperative's 00:06:58.350 --> 00:07:00.829 Um and just to clarify what I heard, there'll be a 00:07:00.829 --> 00:07:05.050 new project opened every year for the annual filing 00:07:05.439 --> 00:07:09.399 a different project or I think there will be a new 00:07:09.399 --> 00:07:13.829 project opened and that will be the same one used annually 00:07:13.860 --> 00:07:20.029 as the current project was used over multi years. Um 00:07:20.040 --> 00:07:23.899 but we're just kind of starting. Okay. I understand 00:07:24.589 --> 00:07:28.279 I have kind of a specific question about one of the 00:07:28.279 --> 00:07:33.129 requirements around the initial E O. P filing, which 00:07:33.129 --> 00:07:37.360 includes an affidavit, affirming that, among other 00:07:37.360 --> 00:07:40.800 things that the entity has conducted a drill to test 00:07:40.810 --> 00:07:44.850 the new E O. P. And the affidavit is an annual requirement 00:07:44.860 --> 00:07:47.839 is my understanding, but for the initial april 15th 00:07:47.850 --> 00:07:51.639 deadline, I guess is the expectation that all utilities 00:07:51.639 --> 00:07:55.029 will have conducted a drill to test their new E O P 00:07:55.029 --> 00:07:59.819 by that time for, you know that Some of them are still 00:07:59.819 --> 00:08:03.009 under development. And so scheduling and conducting 00:08:03.009 --> 00:08:06.670 a drill by April 15, there might be some kind of logistical 00:08:06.680 --> 00:08:09.850 issues with that. So if you have any feedback on that 00:08:10.439 --> 00:08:13.439 Yeah I think in your affidavit you could probably say 00:08:13.449 --> 00:08:15.769 the one that you need to file by April 15. You can 00:08:15.769 --> 00:08:19.889 say this this is a new rule um that applies newly to 00:08:19.889 --> 00:08:25.480 my entity. Um here's my schedule for conducting drills 00:08:25.490 --> 00:08:29.490 this year and we will file something after we've completed 00:08:29.490 --> 00:08:33.419 it in this calendar year. Okay. And and we'll we'll 00:08:33.419 --> 00:08:35.549 accept that. That makes sense because I think there's 00:08:35.549 --> 00:08:40.350 also um the requirement to notify staff with via a 00:08:40.350 --> 00:08:44.600 form, a commission prescribed form within 30 days of 00:08:44.610 --> 00:08:48.860 the date of the drill. And so if we were expected to 00:08:49.240 --> 00:08:53.830 Notice staff 30 days in advance of April 15, where's 00:08:53.830 --> 00:08:57.210 my notice Julia? Yeah well where's the form is the 00:08:57.210 --> 00:09:00.700 form available or? Yeah. So that that's a legacy from 00:09:00.700 --> 00:09:03.820 the rule as it existed prior to the adoption of the 00:09:03.820 --> 00:09:06.440 new rule. And as I understand that there is no specific 00:09:06.440 --> 00:09:10.950 form um that was ever developed. Um So we just you 00:09:10.950 --> 00:09:12.700 know we left the language the same because we tried 00:09:12.700 --> 00:09:15.950 to minimize the number of changes to the current rule 00:09:15.950 --> 00:09:18.929 and just add stuff that needed to be added. And so 00:09:18.940 --> 00:09:23.669 um I think emails are the currently accepted form for 00:09:23.669 --> 00:09:26.850 notifying staff. Okay. That's very helpful. Thank you 00:09:30.740 --> 00:09:33.169 Thank you very much for doing this. Emily jolly with 00:09:33.169 --> 00:09:35.509 L. C. R. A. I don't know if the mics on but 00:09:35.519 --> 00:09:38.480 thank you really appreciate you walking through those 00:09:38.480 --> 00:09:40.929 questions that actually answered a lot of what I wanted 00:09:40.929 --> 00:09:44.360 to cover in particular. The submittal ERCOT um and 00:09:44.360 --> 00:09:48.830 in in in regards to how we submit information to ERCOT 00:09:48.830 --> 00:09:52.299 today there is a secure submittal process and have 00:09:52.299 --> 00:09:54.879 you heard any indication from ERCOT staff about whether 00:09:54.879 --> 00:09:59.320 they intend to use that same portal? Um the encrypted 00:09:59.320 --> 00:10:00.470 submission to ERCOT 00:10:05.720 --> 00:10:09.879 okay sorry Remy Ramaswamy Commission staff I think 00:10:09.879 --> 00:10:12.750 it will be what has been done and ERCOT said they will 00:10:12.750 --> 00:10:15.620 be communicating to all the ERCOT participants by their 00:10:15.620 --> 00:10:18.580 ERCOT notices and their website. So I think that it 00:10:18.580 --> 00:10:21.570 will be and I think the rule also says that all the 00:10:21.570 --> 00:10:26.980 protected information will be held in in the as prescribed 00:10:26.980 --> 00:10:29.659 in the protocols so it will continue in the same format 00:10:30.539 --> 00:10:33.370 Thank you Romeo. Uh The other question I had on that 00:10:33.379 --> 00:10:35.879 is if in the event we have to make an update to 00:10:35.879 --> 00:10:38.590 the commission based on significant changes in that 00:10:38.590 --> 00:10:41.870 language and the rule today, will we also be required 00:10:41.870 --> 00:10:45.820 to make that update to ERCOT Okay, I don't think that's 00:10:45.820 --> 00:10:48.149 in the text of the rule but that's helpful clarification 00:10:52.929 --> 00:10:57.429 other questions. Sure. Um Good morning ned Bonkowski 00:10:57.429 --> 00:11:00.740 with vista um thank you for doing this this morning 00:11:00.750 --> 00:11:04.169 I know this has been a big lift to get this rule 00:11:04.179 --> 00:11:06.850 done and over the finish line and a lot of questions 00:11:07.240 --> 00:11:12.179 your time and efforts are much appreciated. Um you 00:11:12.179 --> 00:11:14.590 already hit on several of the questions and my colleagues 00:11:14.590 --> 00:11:16.610 here also hit on some of the other ones I had, but 00:11:16.620 --> 00:11:20.990 just to attack on, you know, the joint filing is, I 00:11:20.990 --> 00:11:26.539 think a really helpful efficiency provisions. So, you 00:11:26.539 --> 00:11:28.940 know, you're not duplicating efforts both for mark 00:11:28.940 --> 00:11:32.299 participants and for y'all in reviewing them and you 00:11:32.299 --> 00:11:37.399 know, in your reporting. Ah and so I understand the 00:11:37.409 --> 00:11:40.889 need and rationale behind having, you know, entities 00:11:40.889 --> 00:11:43.990 that filed jointly be jointly liable for them. But 00:11:43.990 --> 00:11:46.559 I do want to see if there's any indication just 00:11:48.220 --> 00:11:53.240 to be sure that there's not a double enforcement risk 00:11:53.250 --> 00:11:54.990 associated with that, you know, as we're developing 00:11:54.990 --> 00:11:57.559 plans. It's helpful to understand, you know, if you 00:11:57.559 --> 00:12:01.019 take a joint approach, does that increase regulatory 00:12:01.019 --> 00:12:05.690 risk or, you know, the words that, you know, you're 00:12:05.690 --> 00:12:08.070 held jointly liable, but, you know, the same, the same 00:12:08.070 --> 00:12:11.690 level of risk applies. So, so many people have heard 00:12:11.690 --> 00:12:15.320 me say this and I will say it again and we'll be 00:12:15.320 --> 00:12:18.039 happy to say it again in the future that there will 00:12:18.039 --> 00:12:20.820 be no predetermination on any outcome of any enforcement 00:12:20.820 --> 00:12:23.980 investigation because they're all facts specific. Um 00:12:23.990 --> 00:12:28.200 so the provisions to allow affiliated entities to file 00:12:28.200 --> 00:12:31.899 a single plan was for bureaucratic efficiency for primarily 00:12:31.899 --> 00:12:35.559 for y'all. Um, it's helpful for us as well, but it 00:12:35.570 --> 00:12:39.279 was mostly in a concession to, to ERCOT participants 00:12:39.289 --> 00:12:42.610 So, um, you know, use it and use it wisely 00:12:44.340 --> 00:12:46.610 somewhat expected that that response, but I had to 00:12:46.610 --> 00:12:47.360 ask, okay, 00:12:51.240 --> 00:12:53.320 we can come back to you to know that if you're going 00:12:53.320 --> 00:12:55.279 to think about other questions or you can keep the 00:12:55.279 --> 00:12:56.039 mic. It's up to you. 00:12:58.039 --> 00:13:01.429 Hi marty Hopkins with ever shed Sutherland and um it's 00:13:01.440 --> 00:13:05.100 related to joint filing as well. Uh again, thanks thanks 00:13:05.100 --> 00:13:08.190 for setting up the workshop marty. I'm sorry marty 00:13:08.190 --> 00:13:11.289 could you just say who you're here on behalf of today 00:13:11.299 --> 00:13:17.490 Yes. Um on behalf of multiple entities, jupiter power 00:13:17.500 --> 00:13:25.029 and um text jen and had had questions about the joint 00:13:25.029 --> 00:13:30.480 filing. If you're filing a joint plan and let's say 00:13:30.490 --> 00:13:34.860 uh representing multiple P. G. C. S. Who would you 00:13:34.860 --> 00:13:38.120 actually file? The, the plan? Like this is very practical 00:13:38.120 --> 00:13:41.320 and technical but like who is the filing entity? Is 00:13:41.320 --> 00:13:43.940 it the, is it the parent, even though the parent is 00:13:43.940 --> 00:13:46.690 not a P. G. C. You see what I'm saying? 00:13:51.840 --> 00:13:57.980 So I think the rule contemplates that the filing entity 00:13:57.990 --> 00:14:03.080 is an entity to whom the rule applies. So if the parent 00:14:03.080 --> 00:14:04.759 company is not 00:14:06.299 --> 00:14:10.960 required to file the plan that gets a little goofy 00:14:12.720 --> 00:14:18.049 and so perhaps one of the the entities, the affected 00:14:18.049 --> 00:14:21.299 entities. If I can use that loosely for a moment, were 00:14:21.299 --> 00:14:24.220 to file on behalf of all the other affected entities 00:14:24.230 --> 00:14:27.759 then that might you might cover it. Okay, thank you 00:14:33.240 --> 00:14:35.929 Good morning, will do boys for Southwestern public 00:14:35.929 --> 00:14:39.289 service company. Good morning, good morning. A couple 00:14:39.289 --> 00:14:43.960 of parts on related to paragraph D. On 00:14:45.549 --> 00:14:49.139 the placement of the confidential materials for non 00:14:49.139 --> 00:14:53.600 ERCOT utilities. I know you touched on that, but I 00:14:53.610 --> 00:14:57.549 guess in particular are you envisioning potentially 00:14:58.340 --> 00:15:03.889 being able to have the materials located in Austin 00:15:03.889 --> 00:15:06.750 reasonably convenient for commission access, but at 00:15:06.759 --> 00:15:10.330 a site, you know, at a utilities office or something 00:15:10.330 --> 00:15:13.529 along those lines or you looking in a different direction 00:15:13.809 --> 00:15:17.769 on that, we're imagining that when it's time for our 00:15:17.769 --> 00:15:21.639 consultant to come review the non ERCOT entity plans 00:15:21.639 --> 00:15:25.570 that we'll set up meetings here at the commission offices 00:15:25.580 --> 00:15:29.450 for the entities to come and have their plans available 00:15:29.450 --> 00:15:32.169 to the consultant to review and then with the materials 00:15:32.269 --> 00:15:34.450 would there be materials that would have to stay or 00:15:34.450 --> 00:15:37.070 what could those come back? And I'll tell you the context 00:15:37.080 --> 00:15:42.279 is looking at this through the lens of uh public information 00:15:42.289 --> 00:15:45.559 requirements and be able to document control on things 00:15:45.559 --> 00:15:48.190 that may be critical energy infrastructure, information 00:15:48.269 --> 00:15:50.769 and things along those lines. Yeah, we're we're very 00:15:50.769 --> 00:15:53.779 concerned about the security and confidentiality of 00:15:53.779 --> 00:15:57.080 all these plans. Um and so that's a that's a thing 00:15:57.080 --> 00:16:00.580 that we want to make sure we get right. Um and we're 00:16:00.590 --> 00:16:03.169 since we're still in our contract negotiations with 00:16:03.179 --> 00:16:06.799 the vendor that we hope will be providing these services 00:16:06.809 --> 00:16:09.250 um those are conversations that we need to have with 00:16:09.250 --> 00:16:11.409 them about what level of security and clearance they 00:16:11.409 --> 00:16:11.860 have. 00:16:13.740 --> 00:16:17.110 So that's all I can say about that at the moment. Maybe 00:16:17.110 --> 00:16:20.600 a stay tuned. It's a stay tuned and you know, at a 00:16:20.600 --> 00:16:24.480 minimum it will be to come here, have your plan available 00:16:24.480 --> 00:16:27.159 for review here and then you take it home with you 00:16:28.009 --> 00:16:32.000 And if we can arrange for additional security measures 00:16:32.019 --> 00:16:36.980 then we'll talk. And I imagine then similarly, in terms 00:16:36.980 --> 00:16:40.889 of the scope of who would have access to it is probably 00:16:41.139 --> 00:16:45.820 to be determined along similar lines, uh for sure. 00:16:45.830 --> 00:16:49.370 Yeah. Um certainly it won't be broadly available to 00:16:49.370 --> 00:16:52.690 commission staff. Um it'll be limited to really those 00:16:52.690 --> 00:16:56.100 people who are managing the contract and managing the 00:16:56.110 --> 00:17:00.070 program to develop the report for the legislature and 00:17:00.080 --> 00:17:02.809 and that'll be it. And then for the consultants, just 00:17:02.820 --> 00:17:06.230 who in the consultancy needs to be able to review it 00:17:06.240 --> 00:17:09.079 to come up with your industry. Your wide assessment 00:17:09.549 --> 00:17:10.150 Thank you. 00:17:11.700 --> 00:17:13.900 Good morning. David, keen on behalf of CPS energy, 00:17:15.539 --> 00:17:18.519 looking at the requirements to talk about the commission 00:17:18.519 --> 00:17:23.279 staff will determine the applicability and if there 00:17:23.279 --> 00:17:26.680 is sufficient information. Um, I think we got most 00:17:26.680 --> 00:17:28.759 of that covered by just looking for some additional 00:17:28.759 --> 00:17:31.940 context on how we can expect those communications to 00:17:31.950 --> 00:17:35.599 be conducted very formal or and hopefully get some 00:17:35.599 --> 00:17:37.359 collaborations like we're having today where we can 00:17:37.740 --> 00:17:41.259 work through the issues and avoid some, you know, compliance 00:17:41.259 --> 00:17:45.769 more stricter enforcement. So, um 00:17:47.440 --> 00:17:49.690 first of all, I was going to bring this up when we 00:17:49.690 --> 00:17:52.200 get to subsection D and get into the substance of what's 00:17:52.200 --> 00:17:54.980 required in the plans. But um Mackenzie hinted at it 00:17:54.980 --> 00:18:00.680 earlier and and it's worth noting now that um what 00:18:00.690 --> 00:18:03.269 staff will be doing with this information and what 00:18:03.269 --> 00:18:05.190 our consultant will be doing with this information 00:18:05.190 --> 00:18:10.349 is too we won't be assessing individual plans and say 00:18:10.349 --> 00:18:13.890 oh that's a good planner. Oh that's a bad plan. We're 00:18:13.890 --> 00:18:17.259 gonna say we're going to take a look at it and say 00:18:17.269 --> 00:18:20.789 did you meet the requirements of the rule? Did you 00:18:20.789 --> 00:18:24.930 give me a wildfire plane? Yes or no. If it's terrible 00:18:24.930 --> 00:18:27.789 wildfire plan, it's a terrible wildfire plan. But that's 00:18:27.789 --> 00:18:31.769 not our job in this rule to make an assessment about 00:18:32.220 --> 00:18:35.740 the adequacy of that plan. The job in this rule is 00:18:35.740 --> 00:18:39.509 for the commission to report to the legislature about 00:18:39.509 --> 00:18:44.450 the industry's level of preparedness. So to the extent 00:18:44.450 --> 00:18:47.759 that there is something missing from your from your 00:18:47.769 --> 00:18:50.950 E. O. P. When you submit it, I suspect that it will 00:18:50.950 --> 00:18:54.140 be somewhere in between informal and formal communication 00:18:54.150 --> 00:18:56.740 probably in the form of a handwritten, not a handwritten 00:18:56.740 --> 00:18:59.849 letter, you know, individually typed out a letter to 00:18:59.849 --> 00:19:03.259 the company that says you know, you submitted a plan 00:19:03.259 --> 00:19:10.380 without a wildfire annex. You've got five days to to 00:19:10.380 --> 00:19:13.190 fix it. And if you don't then the matter may be referred 00:19:13.190 --> 00:19:15.559 for enforcement. So thank you. 00:19:19.240 --> 00:19:22.160 I've got one more. I I noticed that in um you know 00:19:22.160 --> 00:19:24.769 in the final rule you broke out some of the requirements 00:19:24.779 --> 00:19:27.740 the filing requirements. Um that's now in c. four for 00:19:27.740 --> 00:19:31.900 like the record of distribution the list of of emergency 00:19:31.900 --> 00:19:37.970 contacts affidavit. Um Now those are the big ones that 00:19:37.970 --> 00:19:40.180 are broken out there and it says you know the entity 00:19:40.180 --> 00:19:42.670 must file those following documents in accordance with 00:19:42.670 --> 00:19:47.140 the the deadlines and paragraphs one and 3. Um Do you 00:19:47.140 --> 00:19:50.819 have a preference or a firm expectation that those 00:19:50.819 --> 00:19:53.490 will be filed in the project that will be opened as 00:19:53.490 --> 00:19:57.640 separate filings or do you want the do you want them 00:19:57.640 --> 00:20:00.779 all in the same uh in the same package as the other 00:20:00.779 --> 00:20:03.859 filings as kind of in the same in the same vein as 00:20:03.869 --> 00:20:06.059 you know with some of the rule making comments and 00:20:06.059 --> 00:20:09.480 and um like ERCOT design comments that we've all been 00:20:09.480 --> 00:20:11.730 working on over the last several months. There's been 00:20:11.730 --> 00:20:14.019 a nasty like have the executive summary at the you 00:20:14.019 --> 00:20:16.910 know the last page of the document to just make things 00:20:16.920 --> 00:20:18.940 easier to work through. Is there a specific way that 00:20:18.940 --> 00:20:22.170 would be helpful for y'all and receiving that information 00:20:27.740 --> 00:20:32.349 So I think the rule asks entities to file an executive 00:20:32.349 --> 00:20:37.150 summary and to file a copy of its plan with the confidential 00:20:37.150 --> 00:20:43.569 portions removed and based on how other of your colleagues 00:20:43.750 --> 00:20:47.099 asked questions during the rural adoption phase. I 00:20:47.099 --> 00:20:52.849 think we were imagining that the elements in In c. 00:20:52.849 --> 00:20:56.559 four here would be filed along with the executive summary 00:20:57.039 --> 00:21:01.140 because there were folks who were concerned about changes 00:21:01.140 --> 00:21:04.599 to that information requiring a re filing of the entire 00:21:04.599 --> 00:21:09.910 plan. So along with the executive summary, but it doesn't 00:21:09.910 --> 00:21:12.980 need to be a separate, a separate submission into the 00:21:18.240 --> 00:21:21.859 it's actually a follow up question. Thinking about 00:21:21.869 --> 00:21:26.269 what goes into the annexes and what you were describing 00:21:26.269 --> 00:21:31.559 on the demonstration of having a plan. Um You know 00:21:31.559 --> 00:21:36.829 utility obviously might have its own levels of detail 00:21:36.839 --> 00:21:40.900 on the plan between a plan and a given area between 00:21:40.910 --> 00:21:45.079 different documents, recognizing we have the executive 00:21:45.079 --> 00:21:48.710 summary requirement here at one level and then the 00:21:48.710 --> 00:21:53.430 annex associated with it as another level. Trying to 00:21:53.430 --> 00:21:57.950 think through whether the way this is being approached 00:21:57.950 --> 00:22:02.230 would mean that utility may have a set of material 00:22:02.240 --> 00:22:06.730 that is quote a plan on a subject matter, but doesn't 00:22:06.730 --> 00:22:09.829 necessarily contain everything that the utility may 00:22:09.829 --> 00:22:15.569 have as as backup or modules behind parts of the plan 00:22:15.900 --> 00:22:20.559 And would Because what level are we looking to get 00:22:20.559 --> 00:22:25.490 down to? Is it sufficient to have? I'm not trying to 00:22:25.490 --> 00:22:30.650 say a very general level, but it's something that demonstrates 00:22:30.880 --> 00:22:34.839 the plan lays out what it is but does not reflect all 00:22:34.839 --> 00:22:38.759 the material entity may have. That goes to the subject 00:22:38.769 --> 00:22:42.730 That makes sense. So, I think I understand your question 00:22:42.740 --> 00:22:45.789 Um and I will first say that I think this is probably 00:22:45.789 --> 00:22:48.859 best addressed when we get to subsection D. And eating 00:22:51.440 --> 00:22:53.890 and not to keep you on pins and needles for an answer 00:22:53.890 --> 00:22:56.299 But let's try, you know, future questions, Let's try 00:22:56.299 --> 00:22:58.960 to keep to the subsection. Um 00:23:00.539 --> 00:23:06.329 We're not prescribing how you write your plan. We're 00:23:06.329 --> 00:23:13.089 not prescribing um the level of detail that you submit 00:23:13.089 --> 00:23:15.769 to us. Um 00:23:17.839 --> 00:23:20.650 you have to meet the minimum requirements in the way 00:23:20.650 --> 00:23:23.349 that your entity feels is appropriate for its particular 00:23:23.349 --> 00:23:27.250 circumstances and to the extent that there is information 00:23:27.250 --> 00:23:31.490 missing in our preliminary review. If it means that 00:23:31.490 --> 00:23:36.420 we're unable to assess the overall adequacy of your 00:23:36.420 --> 00:23:40.180 preparedness as part of the industry wide report that 00:23:40.180 --> 00:23:42.990 we have to make, that's when we'll come back and ask 00:23:42.990 --> 00:23:46.940 for some more information and I'm happy to, you know 00:23:46.940 --> 00:23:49.099 take another stab it and answer for you when we get 00:23:49.109 --> 00:23:51.809 to subsections DNA. That's helpful, appreciate it. 00:23:51.809 --> 00:23:55.269 Sorry to jump ahead barksdale. I did have one more 00:23:55.269 --> 00:23:58.240 question on this section. Before we move on. Um on 00:23:58.240 --> 00:24:01.880 c. four b. There is reference to the list of primary 00:24:01.880 --> 00:24:05.390 and backup emergency contacts. I'm curious about your 00:24:05.390 --> 00:24:09.319 expectations for um the folks that we identify here 00:24:09.329 --> 00:24:11.869 and how that relates to our other contact information 00:24:11.869 --> 00:24:15.009 on file with the commission. And thinking particularly 00:24:15.009 --> 00:24:17.670 about your memo recently about making sure that all 00:24:17.670 --> 00:24:20.809 of our information on file with the commission is up 00:24:20.809 --> 00:24:24.079 to date. Are you expecting those to be the same entities 00:24:24.089 --> 00:24:29.059 The same individuals. Um how how is this uh contact 00:24:29.059 --> 00:24:32.299 list going to be used so we can provide the right people 00:24:33.140 --> 00:24:39.200 So one would hope that they're identical um as has 00:24:39.200 --> 00:24:43.230 been noted very recently by my division. Um folks have 00:24:43.230 --> 00:24:46.500 not done a great job of keeping their contact information 00:24:46.500 --> 00:24:51.009 here at the commission up to date. So when we're in 00:24:51.009 --> 00:24:54.920 an emergency and we go to a contact record in our database 00:24:54.930 --> 00:24:58.160 and that contact information is no longer accurate 00:24:59.039 --> 00:25:01.750 We'd like to have a backup method to be able to look 00:25:01.750 --> 00:25:04.779 at and say oh well we know that these guys are filing 00:25:04.779 --> 00:25:08.619 this every year. We know this is probably a more accurate 00:25:08.619 --> 00:25:11.750 list than I mean y'all there were some folks who hadn't 00:25:11.750 --> 00:25:14.769 updated their their database records for you know 10 00:25:14.769 --> 00:25:19.099 or 15 years. So um like I was still listed for Austin 00:25:19.099 --> 00:25:28.029 Energy on some stuff a couple of um months ago. So 00:25:28.039 --> 00:25:29.430 that's the intent there. 00:25:31.940 --> 00:25:36.380 Okay um Thank you for that Alicia um Is it fair to 00:25:36.380 --> 00:25:37.980 say it's the best practice that if you're going to 00:25:37.980 --> 00:25:41.400 update your contact information it should be the the 00:25:41.400 --> 00:25:46.289 contact portal on the puc website. And this and does 00:25:46.289 --> 00:25:48.650 that constitute a significant change that requires 00:25:48.650 --> 00:25:51.150 an update if you have that person changed in the course 00:25:51.150 --> 00:25:54.460 of a year. So I think it's a best practice to make 00:25:54.460 --> 00:25:58.940 sure that the database in the portal is the best and 00:25:58.940 --> 00:26:01.809 most up to date information that you have on file with 00:26:01.809 --> 00:26:06.970 us. Does a change in your emergency contact information 00:26:06.970 --> 00:26:09.460 constitute a significant change to your plan. 00:26:11.240 --> 00:26:11.450 Mhm. 00:26:13.140 --> 00:26:18.099 Um My hot take on it is that since this is information 00:26:18.099 --> 00:26:21.750 that's being asked to be filed along with your executive 00:26:21.750 --> 00:26:26.210 summary that it's not not inherently part of your emergency 00:26:26.210 --> 00:26:27.450 operations plan. 00:26:29.839 --> 00:26:31.460 You know, use your best judgment 00:26:33.240 --> 00:26:38.119 if you if there's a wholesale turnover in your emergency 00:26:38.119 --> 00:26:42.200 management department, just drop a filing in the project 00:26:43.140 --> 00:26:46.089 keep your contact information up to date in the database 00:26:46.279 --> 00:26:48.839 I think I think we'll all be friends after that. Thank 00:26:48.839 --> 00:26:49.049 you 00:26:50.970 --> 00:26:54.880 lisa lisa martin. Austin Energy. Um I want to ask a 00:26:54.890 --> 00:26:59.339 question um clarification question in c four C in the 00:26:59.339 --> 00:27:02.930 affidavit specifically talking about the names training 00:27:02.940 --> 00:27:05.660 and in the proposal for publication, it talked about 00:27:05.670 --> 00:27:09.960 you know, I s 100 B dot b 200 dot be example 00:27:10.039 --> 00:27:13.140 And now it just says the latest. Um and I want to 00:27:13.140 --> 00:27:16.549 understand if the expectation is if there are new versions 00:27:16.549 --> 00:27:20.549 of those trainings, if people are retaking those when 00:27:20.549 --> 00:27:24.450 you, you know, prior to resubmitting the affidavit 00:27:24.450 --> 00:27:27.240 year over year. Yes, that is the expectation that if 00:27:27.240 --> 00:27:31.009 they're if fema updates the training that folks get 00:27:31.009 --> 00:27:35.250 re certified and and I guess my question follow up 00:27:35.250 --> 00:27:38.529 question, if I may is um it seems to me they change 00:27:38.529 --> 00:27:41.660 those trainings in non substantive ways fairly often 00:27:44.240 --> 00:27:48.680 Has that been considered? Um I think there was a change 00:27:48.690 --> 00:27:53.960 I think the B series trainings had been in effect since 00:27:53.960 --> 00:27:57.990 2017 and the A series trainings had been in effect 00:27:57.990 --> 00:28:02.059 since 2004 four. 00:28:04.369 --> 00:28:05.359 So 00:28:07.009 --> 00:28:08.289 I don't see that as 00:28:09.839 --> 00:28:15.359 a significant amount of updates over time. If I'm missing 00:28:15.359 --> 00:28:17.569 something, I, you know, please let me know 00:28:19.440 --> 00:28:21.859 if it's non substantive, if it's, you know, fixing 00:28:21.859 --> 00:28:27.589 typos and you know, I mean like, but common sense can 00:28:27.589 --> 00:28:31.960 prevail here too. Thank you. Thanks. Yeah, 00:28:33.839 --> 00:28:37.519 marty Hopkins, I should have also added E D F as here 00:28:37.519 --> 00:28:42.349 on earth. Um, this is in uh, see to a person seeking 00:28:42.349 --> 00:28:46.470 registration as a P G C uh, MS, meet the or rep 00:28:46.470 --> 00:28:50.829 must meet the filing requirements um, at the time it 00:28:50.829 --> 00:28:53.599 applies for registration or certification of the commission 00:28:53.609 --> 00:29:01.049 um, is the intent uh, here just to, to have the executive 00:29:01.049 --> 00:29:05.000 summary and redacted plan uh, filed in the new project 00:29:05.009 --> 00:29:09.500 prior to the application for registration And is there 00:29:09.500 --> 00:29:12.259 a timing on that? It just needs to be simultaneous 00:29:12.259 --> 00:29:13.460 with or prior to? 00:29:16.039 --> 00:29:19.059 I think the rule says at the time it applies for. So 00:29:19.900 --> 00:29:24.559 I think the most logical reading of that is when the 00:29:24.559 --> 00:29:29.099 entity files its application for registration or certification 00:29:29.109 --> 00:29:33.569 it is simultaneously filing in the project that we 00:29:33.569 --> 00:29:35.670 will open that I was supposed to open yesterday 00:29:37.710 --> 00:29:42.920 the requirements of this rule and you know, does one 00:29:42.920 --> 00:29:46.369 have to come before the other? Does it have to be instantaneously 00:29:46.369 --> 00:29:50.299 simultaneous same day, same day, would would probably 00:29:50.299 --> 00:29:50.740 cover it. 00:29:53.410 --> 00:29:57.490 And I saw your hand. Yeah. Follow up question on the 00:29:57.500 --> 00:30:00.769 names question and it's probably another common sense 00:30:00.769 --> 00:30:05.359 answer, but better asked and answered than um the not 00:30:05.369 --> 00:30:10.039 Um, so Let's say that there's a new series that's released 00:30:10.039 --> 00:30:13.089 on March 10 for example. And you know, we've got five 00:30:13.089 --> 00:30:15.759 days until the March 15 annual filing deadline. 00:30:17.440 --> 00:30:20.160 Is there a little bit of grace period similar to what 00:30:20.160 --> 00:30:23.289 we talked about on the training? Okay, I appreciate 00:30:23.289 --> 00:30:27.750 that. So when you file your attestation, say we recognize 00:30:27.750 --> 00:30:31.809 that a new version was released, we have a plan to 00:30:31.819 --> 00:30:34.619 get our folks trained up. We're gonna meet it by X 00:30:34.619 --> 00:30:38.490 date after X date. Please make a filing that says we 00:30:38.490 --> 00:30:39.859 did what we said we were going to do. 00:30:42.640 --> 00:30:47.200 Okay. And um the other question on that provision is 00:30:47.640 --> 00:30:50.579 you know, it specifies emergency management personnel 00:30:50.589 --> 00:30:55.099 and um, you know, interactions with specific um, you 00:30:55.099 --> 00:30:58.160 know, state, local, federal emergency management officials 00:30:58.640 --> 00:31:02.940 and so in trying to scope that out, you know, does 00:31:02.940 --> 00:31:03.269 that, 00:31:06.619 --> 00:31:09.619 is that primarily folks that will be interacting for 00:31:09.619 --> 00:31:13.069 instance with the State Operations Center? Um you know 00:31:13.069 --> 00:31:16.069 folks that are reaching out to, you know, sean hazard 00:31:16.069 --> 00:31:22.099 and took Bondurant staff? Or is that including like 00:31:22.099 --> 00:31:24.660 a broader swath of saying that, you know, 00:31:27.390 --> 00:31:31.440 government and regulatory affairs personnel that might 00:31:31.440 --> 00:31:37.240 have interactions with with, you know, folks in state 00:31:37.240 --> 00:31:40.930 and local government, but not necessarily, you know 00:31:40.940 --> 00:31:42.950 designated emergency personnel interacting with the 00:31:42.950 --> 00:31:46.420 stock. Does that make sense? It does. And the rule 00:31:46.420 --> 00:31:51.220 says emergency management personnel. So if you just 00:31:51.230 --> 00:31:53.940 to use an example are not considered part of your emergency 00:31:53.940 --> 00:31:58.119 management team at vista? Even though you interact 00:31:58.119 --> 00:32:02.420 with us? The rule would not apply to you. Okay. That's 00:32:02.420 --> 00:32:03.450 helpful. I appreciate that. 00:32:06.920 --> 00:32:10.180 Yes. I have a question on the binding authority. Typically 00:32:10.180 --> 00:32:13.390 in ERCOT and other requirements, you know, municipal 00:32:13.390 --> 00:32:15.500 utilities, do you have a pretty high level of high 00:32:15.500 --> 00:32:18.099 ranking representatives all the way up into the city 00:32:18.099 --> 00:32:21.000 council? So I'm expecting that a binding authority 00:32:21.000 --> 00:32:24.480 someone um for example, like our ceo or general manager 00:32:24.480 --> 00:32:27.529 and not expecting to have a city council on starting 00:32:27.700 --> 00:32:29.559 to David's. That is correct. Thank you. 00:32:35.140 --> 00:32:37.819 Other questions from the folks up here right now or 00:32:37.819 --> 00:32:40.289 anybody else in the audience on subsection C. 00:32:42.539 --> 00:32:47.359 Mackenzie. Did I screw anything up? No. Mm hmm. Okay 00:32:47.359 --> 00:32:49.559 great. So we'll move on to subsection D. 00:32:53.240 --> 00:32:58.960 This part of the rule talks about the general parts 00:32:58.960 --> 00:33:01.890 of an emergency management, sorry, emergency operations 00:33:01.890 --> 00:33:08.319 plan that we require that apply to any kind of emergency 00:33:08.319 --> 00:33:09.349 that might exist. 00:33:12.440 --> 00:33:16.430 Um And also the process by which you are demonstrating 00:33:16.430 --> 00:33:18.769 that you're keeping your um p current 00:33:20.339 --> 00:33:22.460 do you have any questions on subsection D? 00:33:25.839 --> 00:33:27.039 We had no prevailed 00:33:30.079 --> 00:33:31.680 just briefly, 00:33:33.240 --> 00:33:38.430 I guess for like a distribution only utility. Um My 00:33:38.430 --> 00:33:41.440 question is, what what type of content are you expecting 00:33:41.440 --> 00:33:45.670 for the cyber security annex? And the physical security 00:33:45.670 --> 00:33:49.369 incident annex. So why don't we take that up when we 00:33:49.369 --> 00:33:50.410 get to subsection E. 00:33:52.460 --> 00:33:57.839 D. As in dog Emily. I saw you move your mike. Did 00:33:57.849 --> 00:34:00.349 Julia did you have anything else? I'm good thank you 00:34:00.839 --> 00:34:04.950 Um one Question I had around the approval section 00:34:08.139 --> 00:34:11.619 to the extent that there are maybe sub components of 00:34:11.619 --> 00:34:14.289 an A. O. P. That have their own change control procedure 00:34:14.289 --> 00:34:17.710 and distribution records, um they aren't necessarily 00:34:17.710 --> 00:34:21.090 going to align with an overall like Master E. O. P 00:34:21.099 --> 00:34:25.559 Distribution. Is that a concern for you all? If if 00:34:25.559 --> 00:34:29.599 we have multiple versions of this within a larger E 00:34:29.599 --> 00:34:33.250 O. P. That covers cross functions outside of what subject 00:34:33.250 --> 00:34:33.860 to this rule. 00:34:41.940 --> 00:34:47.380 So if you have parts of your plan that are not part 00:34:47.380 --> 00:34:51.690 of the requirements of this rule, a bravo because this 00:34:51.690 --> 00:34:53.980 is a minimum standard. And we hope that you're thinking 00:34:53.980 --> 00:34:56.570 about your specific circumstances more specifically 00:34:56.570 --> 00:35:02.949 than what's in this rule. Um Two if you are providing 00:35:03.030 --> 00:35:05.780 that additional information alongside the rest of your 00:35:05.780 --> 00:35:09.199 plan, then I think we would like to have an understanding 00:35:09.210 --> 00:35:13.860 of the revision control of the entirety of the plan 00:35:17.039 --> 00:35:19.489 Mackenzie will correct me. But I think it is a best 00:35:19.489 --> 00:35:22.710 practice to make sure that there are not multiple versions 00:35:22.710 --> 00:35:25.860 of your plan floating around out there inside your 00:35:25.869 --> 00:35:29.469 entity or here. So as to minimize confusion. 00:35:30.980 --> 00:35:33.719 But at the end of the day, I think it's up to 00:35:33.719 --> 00:35:36.699 you to decide whether you want to share with us that 00:35:36.699 --> 00:35:41.429 you have annexes or plans or procedures that go above 00:35:41.429 --> 00:35:43.179 and beyond the requirements of the rule. 00:35:46.239 --> 00:35:49.559 Okay That's probably not a very helpful answer. We 00:35:49.559 --> 00:35:51.760 can maybe talk one on 1. Okay. 00:35:53.639 --> 00:35:57.050 Did you want to elaborate any anything in that response 00:35:59.539 --> 00:36:07.090 It's just my first inclination is making sure all plans 00:36:07.099 --> 00:36:14.409 are reviewed and updated as necessary. So that is the 00:36:14.409 --> 00:36:19.780 spirit within which this you know the rule. Looking 00:36:19.780 --> 00:36:27.199 at d that revision control history is in um you know 00:36:27.199 --> 00:36:31.900 so we would hope that if you had a portion of an 00:36:31.900 --> 00:36:38.469 E. O. P. Say with more general response practices applicable 00:36:38.469 --> 00:36:43.860 to any emergency that that would simultaneously be 00:36:43.860 --> 00:36:48.789 assessed with specific annexes if that makes sense 00:36:48.800 --> 00:36:52.789 So if you're not looking at your overall I guess like 00:36:52.800 --> 00:36:57.510 response posture to emergencies holistically. That 00:36:57.519 --> 00:37:02.780 is kind of our idea. But maybe you don't have updates 00:37:02.780 --> 00:37:07.659 to your hurricane plan. It's tested works but it's 00:37:07.659 --> 00:37:11.429 dated as staying consistent with us. But maybe you 00:37:11.429 --> 00:37:13.500 have changed other portions of your plan. I don't know 00:37:13.500 --> 00:37:18.210 Maybe we're not understanding the specifics of your 00:37:18.219 --> 00:37:21.690 question. Um You know we're trying to speak in generalities 00:37:21.690 --> 00:37:25.460 I understand and not specific. Yeah I think that's 00:37:25.460 --> 00:37:27.900 a fair example. So if you have a hurricane specific 00:37:27.900 --> 00:37:31.809 set of procedures and it's reviewed by um in my instance 00:37:31.809 --> 00:37:34.050 it would be transmission staff since we don't have 00:37:34.050 --> 00:37:36.500 any generation facilities in a hurricane zone. So that 00:37:36.500 --> 00:37:39.110 would be specifically applicable to that aspect of 00:37:39.110 --> 00:37:43.679 the plan and it has a a record of distribution and 00:37:43.679 --> 00:37:48.170 change control versioning. Um That is separate apart 00:37:48.179 --> 00:37:49.670 from the larger GOP 00:37:51.329 --> 00:37:53.710 you're gonna see a lot of different records of distribution 00:37:53.710 --> 00:37:56.699 and change control across, you know an entity as large 00:37:56.699 --> 00:38:00.570 as L sierra if that's not an issue for y'all. 00:38:02.380 --> 00:38:06.480 I mean Yeah I don't I think that's fine that they're 00:38:06.480 --> 00:38:11.090 not the same you know? But again like I said, I guess 00:38:11.090 --> 00:38:14.269 going back to just the general idea we just want to 00:38:14.269 --> 00:38:20.289 see that it is being distributed and than those, you 00:38:20.289 --> 00:38:23.820 know, dates that there are it's being thought about 00:38:23.829 --> 00:38:28.650 and continually assessed you know? But we're again 00:38:28.650 --> 00:38:32.199 as Sparks Sale has alluded to, I'm not going to say 00:38:32.199 --> 00:38:35.030 necessarily well there should have been a change in 00:38:35.030 --> 00:38:37.719 this year or not because that's not we're not prescribing 00:38:37.719 --> 00:38:41.909 that that is the entities you know, decisions to make 00:38:41.909 --> 00:38:43.829 So I think it's understandable that there would be 00:38:43.829 --> 00:38:44.329 different 00:38:46.119 --> 00:38:50.030 distribution for certain entities like yourself 00:38:51.880 --> 00:38:54.269 and it won't cause alarm that if one section of your 00:38:54.269 --> 00:38:57.739 plan is updated six times in a year and another section 00:38:57.739 --> 00:39:02.349 of your plan is updated once that's not a concern inherently 00:39:02.349 --> 00:39:03.670 a concern. Yeah. 00:39:06.920 --> 00:39:08.630 Other questions on subsection D. 00:39:12.230 --> 00:39:16.940 Okay moving on to e. This lays out the minimum required 00:39:17.880 --> 00:39:18.670 annexes 00:39:20.219 --> 00:39:24.449 of different specific kinds of emergencies that we 00:39:24.449 --> 00:39:27.539 think everybody needs to be planning for. 00:39:29.619 --> 00:39:33.039 Um Mackenzie what questions did we have 00:39:35.219 --> 00:39:39.750 um As I know there was already a question on this and 00:39:39.750 --> 00:39:43.690 we had a couple pre filed. Um So this is relating to 00:39:43.699 --> 00:39:46.929 specifically the cyber and physical security annex 00:39:46.929 --> 00:39:52.369 is um what information should be included to meet the 00:39:52.369 --> 00:39:56.840 requirements and expectations? Um I'm sorry if I'm 00:39:56.849 --> 00:40:02.239 maybe a broken record at this point. Um but that is 00:40:02.239 --> 00:40:06.730 not for us to say um we want you to have a 00:40:06.730 --> 00:40:11.210 plan. Um So again, if you submitted something and there 00:40:11.210 --> 00:40:17.260 was nothing addressing um cyber incidents for example 00:40:17.269 --> 00:40:20.960 then that that's at the level that we would look and 00:40:20.960 --> 00:40:26.619 see that this is incomplete or inadequate. Um But that 00:40:26.619 --> 00:40:30.829 is for each entity, you know to assess and do that 00:40:31.610 --> 00:40:37.730 um on their own and we're not prescribing any content 00:40:38.309 --> 00:40:43.530 Um So and I know for those um there was a more 00:40:43.530 --> 00:40:46.880 specific question regarding including in the U. P. 00:40:46.880 --> 00:40:52.840 A copy of the Newark cybersecurity policy um if that 00:40:52.840 --> 00:40:55.780 is your plan, you know, it's your plan. Again we're 00:40:55.780 --> 00:40:58.849 not going to say that there should be anything in addition 00:40:58.860 --> 00:41:04.889 or that is not sufficient, but we want an annex addressing 00:41:04.889 --> 00:41:07.900 those in addition to hurricanes and weather emergencies 00:41:07.900 --> 00:41:14.659 And um but as all annexes, I guess we're not saying 00:41:14.659 --> 00:41:18.230 what should be in there. Um 00:41:23.969 --> 00:41:26.829 So Julia will go to you first, since you wanted to 00:41:27.610 --> 00:41:32.329 bring up e a minute ago unless you want to differ. 00:41:32.909 --> 00:41:36.039 Yeah. Thanks Barksdale. I think Mackenzie kind of got 00:41:36.050 --> 00:41:38.469 to where what I was looking for? 00:41:40.809 --> 00:41:45.690 Go ahead. Emily thank you. We're still struggling a 00:41:45.690 --> 00:41:49.510 little bit with the distinct from appreciate the modification 00:41:49.510 --> 00:41:51.550 from the original language of separate and distinct 00:41:51.550 --> 00:41:54.780 from the weather preparations required under the weatherization 00:41:54.780 --> 00:41:58.559 rule. Um, but, but what are you looking for on distinct 00:41:58.559 --> 00:42:04.650 from? So this is, it's about the time horizon. So 25 00:42:04.650 --> 00:42:10.070 55 is a longer term time horizon where you say I have 00:42:10.070 --> 00:42:13.610 a season coming up, I have a certain number of things 00:42:13.610 --> 00:42:17.070 that I need to do to be ready for that season setting 00:42:17.070 --> 00:42:19.070 up windbreaks taking down when breaks that kind of 00:42:19.070 --> 00:42:25.599 stuff. This rule is about what happens in the 72 hours 00:42:25.610 --> 00:42:30.880 96 hours before an event happens. There's a there's 00:42:30.880 --> 00:42:33.920 a hurricane coming. We know it's in the gulf of Mexico 00:42:34.219 --> 00:42:38.539 it's gonna make landfall in two days. What different 00:42:38.539 --> 00:42:42.940 things are we doing to be prepared for the landfall 00:42:42.940 --> 00:42:46.980 of that hurricane on my service territory to make sure 00:42:46.980 --> 00:42:50.650 that I am prepared to respond to that specific emergency 00:42:51.469 --> 00:42:56.610 as opposed to this season. So if it's the case that 00:42:56.610 --> 00:43:01.860 an entity has a procedure that has checklists and specific 00:43:01.860 --> 00:43:06.449 action plans that include both time horizons. But it's 00:43:06.449 --> 00:43:10.769 the same document. Is that going to raise an issue 00:43:10.769 --> 00:43:11.929 on distinct from. 00:43:14.900 --> 00:43:18.840 So it's a two part answer the first is we are not 00:43:18.840 --> 00:43:23.099 making a qualitative assessment of the Adequacy of 00:43:23.099 --> 00:43:27.989 any individual plan or annex. We are using the information 00:43:27.989 --> 00:43:31.320 that will be filed to make an assessment of the industry's 00:43:31.320 --> 00:43:35.309 level of preparedness as a whole. And if we see that 00:43:35.780 --> 00:43:37.949 75% of utilities 00:43:39.599 --> 00:43:43.250 Have considered that seasonal preparedness equates 00:43:43.250 --> 00:43:48.019 to emergency preparedness. That may result in a recommendation 00:43:48.019 --> 00:43:51.829 to refine our rules in one form or fashion to make 00:43:51.829 --> 00:43:54.590 that distinction more clear. Yeah, I do want to clarify 00:43:54.590 --> 00:43:58.000 it's not a question of the same procedures being seasonal 00:43:58.010 --> 00:44:01.420 it might be an instance where the document itself has 00:44:01.429 --> 00:44:04.280 Here's what we do when the forecasted weather storm 00:44:04.289 --> 00:44:07.699 is 24 and 48 hours away. If that's what you do contained 00:44:07.699 --> 00:44:10.320 in the same document, if that's what you do, that's 00:44:10.320 --> 00:44:15.650 what you do and that would satisfy the requirements 00:44:15.650 --> 00:44:16.510 of the rule in my mind. 00:44:24.019 --> 00:44:25.920 Sorry, I was I guess um 00:44:27.679 --> 00:44:32.650 the distinct thought and those who are on weatherization 00:44:33.079 --> 00:44:42.730 chime in. Um I think here for some entities um you 00:44:42.730 --> 00:44:47.300 know, want to ensure to that it is not just the preparedness 00:44:47.889 --> 00:44:51.369 that it's thought about, but the the response, 00:44:53.489 --> 00:44:57.559 so again, it's possible that that could all be contained 00:44:57.570 --> 00:45:01.610 in one document in some cases. Um but we are looking 00:45:01.610 --> 00:45:07.159 at a very broad swath of types of entities um and sizes 00:45:07.170 --> 00:45:11.969 different levels of maturity, ease in um in this, you 00:45:11.969 --> 00:45:15.550 know, emergency preparedness. Um and so that was where 00:45:15.550 --> 00:45:18.440 the distinct came from. I guess two more specifically 00:45:18.440 --> 00:45:22.139 answer that question. So there is preparedness, but 00:45:22.139 --> 00:45:27.500 then there's also actual response to an emergency, 00:45:30.079 --> 00:45:32.780 that's a really good clarification. Mackenzie, thank 00:45:32.780 --> 00:45:39.039 you. And as an example of that You might in your preparations 00:45:39.039 --> 00:45:45.300 under 25.55 say I'm going to stockpile salt so that 00:45:45.309 --> 00:45:48.039 if there's a freezing and icing event I can Sprinkle 00:45:48.039 --> 00:45:54.300 it on my side, walks around my power plant, your whether 00:45:54.300 --> 00:45:59.940 emergency nx might say employee X. Goes to salt pile 00:46:00.230 --> 00:46:05.199 and sprinkles 12 hours prior to expected icing. 00:46:06.769 --> 00:46:08.599 That's what we mean by the distinct. 00:46:13.480 --> 00:46:16.699 I've got one it's probably more a comment because I've 00:46:16.699 --> 00:46:18.409 heard you say a number of times now, you know, you're 00:46:18.409 --> 00:46:22.389 not not necessarily dictating the exact contents more 00:46:22.389 --> 00:46:27.239 the completeness of the plan. Um but I know you know 00:46:27.239 --> 00:46:31.909 we are I'm particularly interested in the Contents 00:46:31.909 --> 00:46:36.230 of E one H which is the provision that um you know 00:46:36.230 --> 00:46:40.989 covers pure 39 9 18 B one in particular. That's the 00:46:41.579 --> 00:46:44.500 um transmission and distribution utilities at least 00:46:44.510 --> 00:46:46.980 or operating facilities in this case it's basically 00:46:46.980 --> 00:46:50.000 mobile generators and there are provisions in B one 00:46:50.010 --> 00:46:56.210 um pier 39 9 18 that um you know dictate the the 00:46:56.210 --> 00:47:00.090 use of those resources and some of the protections 00:47:00.090 --> 00:47:05.119 for the ERCOT. You know there are metering and therefore 00:47:05.130 --> 00:47:08.960 ERCOT settlement impacts so that may not be appropriate 00:47:08.960 --> 00:47:12.219 for this. But you know that is something that I think 00:47:12.230 --> 00:47:14.099 a lot of ERCOT participants would have an interest 00:47:14.099 --> 00:47:18.239 in um you know and having some clarity about how those 00:47:18.250 --> 00:47:22.670 will be implemented. So more of a more of a comment 00:47:22.679 --> 00:47:25.719 But yeah I think that's outside of the scope of what 00:47:25.719 --> 00:47:27.090 we're doing in the room. Okay. 00:47:32.380 --> 00:47:36.590 Other questions about annex. E as an elephant, 00:47:40.579 --> 00:47:42.289 wow, awesome. 00:47:45.280 --> 00:47:50.750 Okay moving right along let's go on to f drills. This 00:47:50.750 --> 00:47:54.110 is the section that requires drilling to occur every 00:47:54.110 --> 00:47:57.300 year unless you have an activation of your plan. 00:48:00.070 --> 00:48:03.719 Questions that we got pre filed. Um So he had quite 00:48:03.719 --> 00:48:08.400 a few and I know we've already sort of discussed some 00:48:08.400 --> 00:48:14.079 of them um but first I will go to the notification 00:48:14.199 --> 00:48:17.260 um you know we had questions about the language in 00:48:17.260 --> 00:48:22.570 the rule speaking of letting the commission um and 00:48:22.570 --> 00:48:25.599 Tedium district coordinators know um and then by the 00:48:25.599 --> 00:48:31.000 puc website form. So yes there is no form officially 00:48:31.010 --> 00:48:34.519 Um and I know currently the practices to submit a letter 00:48:34.530 --> 00:48:42.440 in the current GOP docket, we are working on updating 00:48:42.440 --> 00:48:46.070 our website with information. There is a specific email 00:48:46.070 --> 00:48:49.690 address that will be on there which will satisfy the 00:48:49.690 --> 00:48:57.130 notification to the commission. Um And there will be 00:48:57.139 --> 00:49:01.769 again, further explanation there um to be determined 00:49:01.769 --> 00:49:05.440 still I think some of it whether we will want something 00:49:05.440 --> 00:49:10.050 filed in the docket as well, a letter stating um you 00:49:10.050 --> 00:49:13.659 know a drill is occurring or that the U. P. Has been 00:49:13.659 --> 00:49:18.190 activated but that information should be up on our 00:49:18.190 --> 00:49:23.280 website soon likely under our storm resources page 00:49:23.670 --> 00:49:29.440 So that was the question, you know we um there was 00:49:29.440 --> 00:49:34.340 another question about um, if notifying both the puc 00:49:34.349 --> 00:49:38.420 and uh tetum officials would mean that there would 00:49:38.420 --> 00:49:41.539 be representatives from either the commission and or 00:49:41.539 --> 00:49:48.400 tetum at the drills. Um Yes, there could be um we have 00:49:48.590 --> 00:49:52.889 in the past attended some drills so there will be, 00:49:54.099 --> 00:49:58.789 you know, communication they're of and again it's just 00:49:58.800 --> 00:50:05.860 participatory observation. Um and Then I think we touched 00:50:05.860 --> 00:50:09.320 on again already if drills have not occurred prior 00:50:09.320 --> 00:50:13.460 to the April 15 um deadline, what to do in that case 00:50:13.460 --> 00:50:17.369 So those are the other questions um About satisfying 00:50:17.369 --> 00:50:20.690 that requirement before the April 15 filing deadline 00:50:23.659 --> 00:50:28.030 So I've got a question along those lines. Um for the 00:50:28.030 --> 00:50:31.750 drills, does that include for instance, tabletop exercises 00:50:31.760 --> 00:50:34.449 that, you know, might be coordinating across a number 00:50:34.449 --> 00:50:38.880 of entities. Um so joint drills across entities and 00:50:38.889 --> 00:50:43.699 you know, that are affiliated. Um you know, if, and 00:50:43.710 --> 00:50:45.840 does it have to be a physical drill or can it also 00:50:45.840 --> 00:50:48.500 be working through procedures and in the coordination 00:50:48.500 --> 00:50:53.840 process? Um that occurs at a higher level going um 00:50:53.849 --> 00:50:59.429 Yes, I think tabletops and exercising our fine, but 00:50:59.429 --> 00:51:04.440 they're not, you know, physical in a sandbox. Everyone 00:51:04.440 --> 00:51:08.449 I wanted to clarify that just because as a probably 00:51:08.449 --> 00:51:11.530 an order of magnitude in terms of planning and right 00:51:11.539 --> 00:51:14.780 and the capabilities of different entities, I'm sure 00:51:14.789 --> 00:51:17.139 to conduct different types. But yes, really what we're 00:51:17.139 --> 00:51:21.210 looking, you know, exercising your plans, um, you know 00:51:21.210 --> 00:51:24.639 in practice and then if again as sparks alluded to 00:51:24.639 --> 00:51:28.380 in the rural states, they have not been activated, 00:51:28.840 --> 00:51:31.019 you know, for an emergency. Okay perfect. Thank you 00:51:31.019 --> 00:51:34.579 so much. Kind of along those same lines. I was wondering 00:51:34.579 --> 00:51:38.309 if this requires a separate drill just for this or 00:51:38.309 --> 00:51:40.500 if we can use other drills that were involved in that 00:51:40.500 --> 00:51:43.480 kind of point to those and use those as as our drills 00:51:43.489 --> 00:51:46.800 use critics as an example or no bureaucrat winter storm 00:51:46.800 --> 00:51:49.280 in summer summer jules acceptable 00:51:52.110 --> 00:51:55.340 as long as you're practicing your emergency operations 00:51:55.340 --> 00:51:59.780 plans. Yes and yeah, you know, critics Here's a good 00:51:59.780 --> 00:52:02.420 one. You all, you know, practice portions of it and 00:52:02.420 --> 00:52:07.980 then more specifically, um other annexes. But again 00:52:09.349 --> 00:52:12.550 yes. And then obviously there's a requirement for those 00:52:12.550 --> 00:52:17.260 and hurricane evacuation zones um for that specific 00:52:17.260 --> 00:52:21.380 hurricane related exercise. So thank you 00:52:22.949 --> 00:52:28.190 another question along the hurricane exercise for my 00:52:28.190 --> 00:52:30.519 company. Most of our operations are in the north texas 00:52:30.519 --> 00:52:32.809 area, In west texas kind of outside of that hurricane 00:52:32.809 --> 00:52:35.340 zone. We do have, you know, occasional satellite offices 00:52:35.340 --> 00:52:38.460 Like we've got one here in Austin one in Houston. Um 00:52:38.469 --> 00:52:40.889 Houston is probably the only one that uh, you know 00:52:40.900 --> 00:52:44.710 that would be in that area, but you know, is a basically 00:52:44.710 --> 00:52:47.809 a retail sales office. Is that something that you would 00:52:47.820 --> 00:52:51.070 expect to have the drill for? Are you looking more 00:52:51.070 --> 00:52:56.389 for like the core operations of the retail for instance 00:52:56.389 --> 00:53:00.260 you know, customer service billing um complainin takes 00:53:00.260 --> 00:53:03.800 things like that. Um Yeah, I mean let's say this is 00:53:03.800 --> 00:53:05.570 a use your best judgment 00:53:07.449 --> 00:53:13.059 kind of example where you have assessed for your operations 00:53:13.070 --> 00:53:20.780 Yeah, decor. Um and going from there, I will also kind 00:53:20.780 --> 00:53:22.710 of insert here. I know there have been questions on 00:53:22.719 --> 00:53:28.300 finding tetum hurricane evacuation zones. Um So we 00:53:28.300 --> 00:53:30.469 are also in the process of working with tetum to get 00:53:30.480 --> 00:53:37.139 that information um on their website. But there are 00:53:37.139 --> 00:53:41.340 ways I know Tina directs people to call 211 and you 00:53:41.340 --> 00:53:44.110 can find out if you're in a hurricane evacuation zone 00:53:44.119 --> 00:53:49.539 Um So again also stay tuned and we will link to that 00:53:49.550 --> 00:53:52.860 in our storm resources information when we get that 00:53:52.860 --> 00:53:55.760 updated as well. So it'll be easier to find 00:54:02.429 --> 00:54:03.559 other questions on drills. 00:54:12.739 --> 00:54:16.880 Good morning Liz jones for encore. If we are participating 00:54:16.889 --> 00:54:20.159 in an ERCOT drill, do we need to separately notice 00:54:20.159 --> 00:54:20.469 you? 00:54:27.739 --> 00:54:30.239 I think the rule says that you need to separately notice 00:54:30.239 --> 00:54:38.059 at least one annual drill. So if the ERCOT drill is 00:54:38.059 --> 00:54:41.460 the only one that you're doing then. No, 00:54:44.840 --> 00:54:47.440 no, I don't know. I don't have to notice that you don't 00:54:47.440 --> 00:54:49.360 have to notice that. Okay, thank you. 00:54:54.639 --> 00:54:57.420 I'm sorry, Liz, let me clarify that just a little bit 00:54:57.429 --> 00:54:58.059 better. 00:55:05.349 --> 00:55:08.400 Sorry, this is a question that I hadn't anticipated 00:55:08.730 --> 00:55:13.059 nor nor nor did I think of it until just now. So 00:55:13.639 --> 00:55:19.960 for instance or cut sponsors and coordinates grid X 00:55:19.960 --> 00:55:24.010 Participation by a number of entities and they are 00:55:24.010 --> 00:55:28.250 entirely responsible for, they pick an event so they'll 00:55:28.250 --> 00:55:30.699 pick an ice storm or they'll pick a hurricane and they'll 00:55:30.699 --> 00:55:35.349 build a drill around that. And so it's extremely helpful 00:55:35.739 --> 00:55:40.170 for both ERCOT participants and ERCOT too be a part 00:55:40.179 --> 00:55:45.170 of those drills. I'm just asking if you want, you know 00:55:47.239 --> 00:55:54.239 200 for example participants to separately file on 00:55:54.239 --> 00:55:58.690 this GOP or you know, is there is there some other 00:55:58.690 --> 00:56:02.409 bureaucratic efficiency that we could use in thinking 00:56:02.409 --> 00:56:06.610 about this? So I have to completely reverse my original 00:56:06.610 --> 00:56:09.429 answer and say yes, we do want to be notified if this 00:56:09.429 --> 00:56:13.670 is the one annual drill that you will be doing, we 00:56:13.670 --> 00:56:15.460 need to know that this is the one that you will be 00:56:15.460 --> 00:56:19.119 doing now. Whether there is a bureaucratic efficiency 00:56:19.119 --> 00:56:23.289 that we could all kind of kumbaya around. I suspect 00:56:23.289 --> 00:56:25.800 there is and maybe that's working through ERCOT to 00:56:25.800 --> 00:56:29.559 provide us a list of participants, You know 30 days 00:56:29.559 --> 00:56:33.920 in advance if if such a list should exist. Um, and 00:56:33.920 --> 00:56:36.110 those answers I don't know about. I don't know if the 00:56:36.329 --> 00:56:37.159 two of you know, 00:56:39.530 --> 00:56:42.170 um I'm going to take a stab at answering this question 00:56:42.170 --> 00:56:46.289 barksdale, I hope I'm not gonna lie completely. I actually 00:56:46.289 --> 00:56:48.389 participated in one of those drills last year just 00:56:48.389 --> 00:56:52.559 to observe this. I would actually say no, I don't think 00:56:52.570 --> 00:56:56.210 that is what we mean by what we mean in our drills 00:56:56.219 --> 00:56:59.239 Um, and I mean I know the drill that you know like 00:56:59.250 --> 00:57:03.280 the severe storm um weather drill for example or the 00:57:03.280 --> 00:57:09.800 load shed exercise that was also done. Um I think the 00:57:09.800 --> 00:57:15.769 way the rule is written is these are drills that applies 00:57:15.769 --> 00:57:21.070 to the entities and what they would be doing. Um Not 00:57:21.079 --> 00:57:23.949 an ERCOT sponsored drill. So 00:57:26.030 --> 00:57:29.219 then I got to tell you I don't know how to comply 00:57:29.230 --> 00:57:33.590 with this requirement because internally we had assumed 00:57:34.000 --> 00:57:38.849 that if we want to talk about Drilling on a particular 00:57:38.849 --> 00:57:42.980 issue we would use that ercot experience. Now it may 00:57:42.980 --> 00:57:47.809 be that I have to tell you about four different exercises 00:57:47.809 --> 00:57:53.019 that constitute the totality of drilling on my E. O 00:57:53.019 --> 00:57:59.110 P. But I don't know that we have constructed 00:58:01.320 --> 00:58:06.329 that we have a vision of what a an encore only E 00:58:06.329 --> 00:58:08.829 O. P. Drill would look 00:58:12.980 --> 00:58:16.829 then maybe I'm wrong I just but you know jumped into 00:58:16.829 --> 00:58:19.340 it. I don't I don't know maybe I should just stop there 00:58:20.219 --> 00:58:22.739 So I I wasn't gonna ask the question but now I feel 00:58:22.739 --> 00:58:25.110 like I need to we do a lot of drills and I 00:58:25.119 --> 00:58:27.559 think I interpreted your initial answer is we don't 00:58:27.559 --> 00:58:31.030 have to notify you of every drill we just need to do 00:58:31.039 --> 00:58:35.250 one notification of one drill each year for this procedure 00:58:35.719 --> 00:58:37.679 is that accurate? Is accurate? 00:58:40.420 --> 00:58:43.920 So what I think the correct thing to do at this point 00:58:43.920 --> 00:58:48.829 Liz is huddle with Romania and the rest of the team 00:58:48.840 --> 00:58:52.110 just to make sure that we're on the same page about 00:58:52.110 --> 00:58:56.530 what an ERCOT sponsored drill looks like. Thanks. My 00:58:56.530 --> 00:59:00.239 understanding of the rule is that if you are practicing 00:59:00.250 --> 00:59:06.510 your plan, Whether it's on your own or through a 3rd 00:59:06.510 --> 00:59:10.440 party sponsored event, that's what we're looking for 00:59:12.320 --> 00:59:16.340 And so to the extent that there is an ERCOT sponsored 00:59:16.900 --> 00:59:23.039 exercise in which you get to practice your specific 00:59:23.039 --> 00:59:27.139 response vis a vis that exercise, I think that should 00:59:27.150 --> 00:59:31.449 be sufficient. But I want to talk more with Romeo about 00:59:31.460 --> 00:59:36.420 her perspective and what she experienced and and then 00:59:36.429 --> 00:59:40.539 we'll follow up with I guess we probably should drop 00:59:40.539 --> 00:59:45.199 something in the project just to clarify that. Yes 00:59:45.199 --> 00:59:48.190 please. Thank you. Thanks for raising the question 00:59:48.190 --> 00:59:48.539 is good. 00:59:54.219 --> 00:59:57.960 My next Sure, thank you barksdale, thank you for holding 00:59:57.960 --> 01:00:00.139 the workshop. I appreciate the information has been 01:00:00.139 --> 01:00:04.550 very helpful. The from the rep could you just identify 01:00:04.550 --> 01:00:06.590 Yes, I'm sorry I meant to do that. Eric Blakey and 01:00:06.590 --> 01:00:11.090 with just energy, The perspective of the rep and section 01:00:11.090 --> 01:00:16.269 three and the requirements. Um well that was in section 01:00:16.280 --> 01:00:19.599 E but just looking at at the GOP requirements and then 01:00:19.599 --> 01:00:22.670 thinking about a drill and looking at the drill and 01:00:22.670 --> 01:00:27.300 it talks about at least one of the drills um needs 01:00:27.300 --> 01:00:31.599 to test the hurricane piece of the annex, if you operate 01:00:31.599 --> 01:00:33.750 in a hurricane zone. And so I just want to confirm 01:00:33.750 --> 01:00:37.909 that if we have an office in Houston that would, that 01:00:37.909 --> 01:00:40.820 would trigger that hurricane provisions is what you're 01:00:40.820 --> 01:00:49.010 thinking? Yes. Okay. And so if it says this about a 01:00:49.010 --> 01:00:52.750 drill for uh companies that operate in a hurricane 01:00:52.750 --> 01:00:55.320 zone, that at least one of the drills must include 01:00:55.329 --> 01:01:00.940 a test of the hurricane. Ah annex correct, correct 01:01:01.409 --> 01:01:06.840 So, does that by default mean that unless we've had 01:01:06.840 --> 01:01:12.110 a hurricane, we have to have a hurricane drill because 01:01:12.110 --> 01:01:14.860 we could use a hurricane, a real hurricane as a test 01:01:14.860 --> 01:01:17.949 of our plan and we could use that as our as our 01:01:17.949 --> 01:01:20.829 drill. But if if we don't have that, it doesn't matter 01:01:20.829 --> 01:01:22.510 if we've tested the other things. We need to have a 01:01:22.510 --> 01:01:25.730 hurricane test. Your logic is correct. Thank you. Thanks 01:01:29.010 --> 01:01:30.139 Did you have another question. 01:01:33.210 --> 01:01:35.730 It smells are wanting to participate. 01:01:37.409 --> 01:01:39.019 He looks like it. Mhm. 01:01:40.809 --> 01:01:43.159 You don't have to just You look like you want to say 01:01:43.159 --> 01:01:45.739 something if we're 01:01:48.909 --> 01:01:50.380 that was maybe different than I thought, but Well, 01:01:50.599 --> 01:01:53.230 if we're filing a clarification memo on that, if I 01:01:54.309 --> 01:01:55.329 we can mention it, then too, 01:01:58.110 --> 01:02:00.519 maybe barksdale has a totally misunderstanding of what 01:02:00.519 --> 01:02:01.519 this section says, 01:02:04.500 --> 01:02:10.670 that provides a lot of confidence. We passed this thing 01:02:10.670 --> 01:02:13.929 off in stages. And so uh that happened, 01:02:16.900 --> 01:02:19.199 we will definitely file something and will file something 01:02:19.199 --> 01:02:23.340 very quickly. So, as to clarify. Staff's understanding 01:02:23.349 --> 01:02:24.929 of subsection F. 01:02:27.699 --> 01:02:31.469 We certainly don't want there to be confusion or misunderstanding 01:02:31.469 --> 01:02:33.949 about how we are reading the rule that the commissioners 01:02:33.949 --> 01:02:37.880 adopted, um we know that you all want to do the right 01:02:37.880 --> 01:02:41.920 thing and make sure that you aren't running afoul of 01:02:41.920 --> 01:02:47.420 any rules. So we will work assiduously and with alacrity 01:02:52.400 --> 01:02:57.070 Okay, moving on to subsection G. Reporting requirements 01:02:59.500 --> 01:03:04.539 Um This is a section that requires you all to be in 01:03:04.539 --> 01:03:08.190 touch with us during an emergency if there's an activation 01:03:08.190 --> 01:03:10.019 of the State Operations Center. 01:03:13.199 --> 01:03:15.639 Do you have questions on subsection G. Did you have 01:03:15.639 --> 01:03:21.940 any profile? Okay, I'll jump in. Thank you. Um So I 01:03:21.940 --> 01:03:25.940 guess I have two questions on this and the first is 01:03:25.949 --> 01:03:30.670 this is a separate um It appears to be a separate requirement 01:03:30.679 --> 01:03:32.650 other than something that needs to be in the E. O. 01:03:32.650 --> 01:03:36.909 P. Are there specific GOP requirements that govern 01:03:37.050 --> 01:03:40.719 what this reporting structure and back and forth looks 01:03:40.719 --> 01:03:45.119 like? And then secondarily, if not, how does this go 01:03:45.500 --> 01:03:46.730 what do you want this to look like 01:03:51.699 --> 01:03:52.099 you want to? 01:03:57.300 --> 01:04:02.610 So I know this is something also in practice that um 01:04:03.150 --> 01:04:09.219 commission staff has provided guidance on um for reporting 01:04:10.090 --> 01:04:16.010 to staff at the sock and what constitutes that? Um 01:04:16.690 --> 01:04:18.929 Can you let me know what that is? I'm not familiar 01:04:18.929 --> 01:04:23.510 with that guidance. Um I can yeah, we can direct you 01:04:24.059 --> 01:04:27.349 Is it something other than outage reporting? Uh No 01:04:27.349 --> 01:04:28.710 that's the main. Okay, 01:04:31.090 --> 01:04:32.809 okay, purpose. 01:04:35.989 --> 01:04:38.570 So the outage reporting requirements and guidance are 01:04:38.570 --> 01:04:41.599 not incorporated into the GOP rule explicitly in the 01:04:41.610 --> 01:04:46.710 in the earlier sections? So Apart from complying with 01:04:46.710 --> 01:04:49.880 that in 25-52, is there something separate that this 01:04:49.880 --> 01:04:51.409 language is requiring of us. 01:04:59.489 --> 01:05:03.199 I think it's just making it explicit that it is during 01:05:03.199 --> 01:05:08.449 an activation of the S. O. C. Whereas in 25 52 it 01:05:08.449 --> 01:05:12.710 is a it's a report on when you have an significant 01:05:12.710 --> 01:05:15.239 interruption in your service territory, irrespective 01:05:15.239 --> 01:05:18.800 of whether there is an activation of the socks. If 01:05:18.800 --> 01:05:21.889 I'm remembering 25 52 correctly, if I'm even starting 01:05:21.889 --> 01:05:25.800 the right role, I didn't look it up. Okay. I think 01:05:25.800 --> 01:05:29.469 that helps. This is you know, pre existing language 01:05:29.469 --> 01:05:33.320 from the rule prior to Yeah, I just we haven't had 01:05:33.320 --> 01:05:36.230 experience with this and so I I don't know what this 01:05:36.230 --> 01:05:40.820 kind of back and forth looks like with staff and it's 01:05:40.820 --> 01:05:43.239 self evident but if there was something more than that 01:05:43.239 --> 01:05:45.750 maybe it's on the page that y'all are expecting from 01:05:45.750 --> 01:05:48.019 folks or what the form of that communication looks 01:05:48.019 --> 01:05:51.559 like or the method of communication or any other details 01:05:51.570 --> 01:05:55.300 that you could provide maybe in guidance memoranda 01:06:00.179 --> 01:06:03.010 Sure we can we can look into that. Thanks. 01:06:05.380 --> 01:06:08.289 I have one question on the the last sentence of subsection 01:06:08.289 --> 01:06:13.920 G. Um for the potential after after event reporting 01:06:14.460 --> 01:06:18.730 um you know, I trust that part of the may staff may 01:06:18.739 --> 01:06:21.159 require filing. It probably has some discretion on 01:06:21.170 --> 01:06:24.610 you know what the event was and um you know, what's 01:06:24.610 --> 01:06:28.639 appropriate to file? Um But to the extent that any 01:06:28.650 --> 01:06:32.210 of that reporting would include um you know confidential 01:06:32.210 --> 01:06:36.099 or security uh related information. Ah 01:06:38.179 --> 01:06:40.329 I'm assuming it would be filed confidentially with 01:06:40.329 --> 01:06:45.329 the commission or possibly through the same uh machinations 01:06:45.329 --> 01:06:47.849 that we can contemplated for filing the unredacted 01:06:47.849 --> 01:06:51.440 GOP with ERCOT and maintaining protected information 01:06:51.440 --> 01:06:54.409 status but having it be available to the commission 01:06:54.980 --> 01:06:58.099 Yes, certainly we'll take confidentiality and security 01:06:58.579 --> 01:07:01.900 into into consideration when we think about what we're 01:07:01.900 --> 01:07:06.710 asking for. If we ask for something, what vehicle and 01:07:06.710 --> 01:07:10.820 medium and method that takes hold, I think it'll be 01:07:10.820 --> 01:07:13.679 fact specific. That makes sense. Thank you. 01:07:16.579 --> 01:07:18.710 Other questions on subsection G. 01:07:22.880 --> 01:07:26.059 Are there any other questions about the rule that you 01:07:26.059 --> 01:07:30.159 don't feel like we addressed aside from the cluster 01:07:30.159 --> 01:07:32.789 That was our response on subsection F. 01:07:34.579 --> 01:07:38.570 Barksdale. Um Just general questions should entities 01:07:38.570 --> 01:07:42.440 expect some kind of confirmation of receipt of the 01:07:42.449 --> 01:07:45.409 GOP. So you'll only hear from you if there's a deficiency 01:07:46.099 --> 01:07:51.489 Okay, thank you With 900 Odd findings that we're expecting 01:07:55.980 --> 01:07:58.670 Uh The last thing that I would say before we all part 01:07:58.670 --> 01:08:04.789 ways for the weekend um is to um encourage your companies 01:08:04.789 --> 01:08:07.800 and your member entities. If you're here on behalf 01:08:07.800 --> 01:08:12.059 of the trade association to please review the proposal 01:08:12.059 --> 01:08:15.829 for adoption. Many of the questions that we received 01:08:15.840 --> 01:08:18.329 pre filed were answered in the proposal for adoption 01:08:18.970 --> 01:08:23.260 Um David staff spent hundreds and hundreds and hundreds 01:08:23.260 --> 01:08:26.470 of hours writing that and it's a long document and 01:08:26.470 --> 01:08:31.800 it's tedious and um it's required by law and nobody 01:08:31.800 --> 01:08:37.069 reads it. So please use the resources that you already 01:08:37.069 --> 01:08:40.819 have available to you because hopefully everything 01:08:40.819 --> 01:08:42.909 that we set up here, with the exception of subsection 01:08:42.920 --> 01:08:45.500 F matches everything that we already said in the proposal 01:08:45.500 --> 01:08:50.350 for adoption and um respect the work that's been done 01:08:50.350 --> 01:08:57.779 on your behalf already. And we love you. And with that 01:08:58.170 --> 01:09:00.899 we will conclude this workshop. Thank you. Thank you 01:09:01.470 --> 01:09:01.680 Thank you.