(item:0.1:Chairwoman Jackson calls meeting to order) Good morning. This meeting of the Public Utility Commission
of Texas will come to order to consider matters that
have been duly posted with the Secretary of State for
September 14, 2023 for the record. My name is Kathleen
Jackson. I'm joined by Will McAdams, Lori Cobos and
Jimmy Glotfelty. Today is our first open meeting with
public comment on individual items as you probably
saw when you arrived this morning, um agenda from our
office of Public Engagement was available to greet
you and help you sign up to speak. We will call you
up for each a agenda. Number, item
(item:0.1:Chairwoman Jackson asks for Public comment for matters not posted) Comments on general matters will still be taken up
under item number one, consistent with our previous
open meetings. Speakers will be limited to three minutes
each and public comment is not available for contested
cases. Let's begin with item number one, general comments
for topics not specifically posted on this agenda.
Sheila, do we have anyone from the public signed up
to speak? No, ma'am. No one has signed up for item
number one. Ok. This completes item number one, (item:0.2:Shelah Cisneros lays out consent agenda) Shelah
will you please walk us through the consent items on
today's agenda? Yes, Good morning commissioners before
I get to the consent agenda, I just want to note that
Commissioner Cobos has recused herself from item number
23 docket number 55155. And then for the consent agenda
by individual ballot, the following items are placed
on your consent agenda. Items 2, 4, 5, 13 through 17, 20, 21,
and 24. (item:0.2:Chairwoman Jackson asks for motion to approve items on consent agenda) I will entertain a motion to approve the items
just described by Shelah. Second. All in favor say
I I motion passes (item:41:Project No. 55153 – Review of § 22.52. - Proposal for Adoption - Not taken up) additionally. Item 41 will not be
taken up. Item number two was consented next up is
(item:3:Shelah Cisneros lays out Application of CSWR-Texas Utility Operating Company) item number three, Sheila, will you please lay out
this item? Yes, ma'am. Item number three is second
number 54393. This is the application of CS Wr Texas
Utility Operating Company and intermediary Solutions
for the sale transfer, merger of facilities and certificate
rights in Lubbock County. Before usa proposed interim
order, CS Wr filed exceptions to the proposed interim
order. The A LJ filed a memo declining to make the
changes to the proposed order. And Commissioner Jackson
filed a memo in this docket. (item:3:Chairwoman Jackson lays out her memo) I filed a memo. I'd like
to discuss several issues regarding capital improvement
plans under statute and commission rule. In the proposed
interim order. The commission administrative law judge
required that CS Wr Texas file a capital improvement
plan before final improvement of the transaction could
be granted. CS Wr Texas provided a third party's engineer
preliminary itemized list of repairs and the estimated
cost, the total cost of necessary capital improvements
and a timeline for repairs. Cr Texas filings collectively
address the capital improvement plan requirements for
a budget, a timeline but do not meet the requirement
for a map. Key to the budget and timeline as required
by 16 24.233 a six. Therefore, I recommend that the
commission make the following changes to the proposed
interim order as described in my memo. So as to be
in compliance with both statute and commission rules
so any thoughts on this? (item:3:Commissioner McAdams agrees with memo) No madam chair, I agree with
your memo. I would move that we adopt a propose in
order as amended by your memo. Ok, thank you one second
Ok, I have a motion and uh, a second to adopt the
proposed interim order, um, including modifications
consistent with my memo. Um, all in favor, say I I
motion passes, um, in, (item:3:Chairwoman Jackson notes thoughts on term - capital improvement plan) in several dockets, I've noticed
that the term capital improvement plan is not well
defined. And, um, Connie, do you think we should clarify
in a rule making? Uh, what should be included in a
capital improvement plan when it's feasible for our
PUC staff to address it? Yes, ma'am. We'll add that
to the list. Ok, thank you very much.
Items, four and five were consented. (item:6:Water and Sewer Utility Rates After Acquisition - Proposal for Publication) Next up is item
number six, project number 53924. This is the commission's
rule making regarding water and sewer utility rights
after acquisition, Sheila. Do we have anyone from the
public signed up to speak on item number six? No, ma'am
no incentive to speak on this item. Ok, thank you.
I want the commission staff filed a memo and a proposal
for publication. Ok. (item:6:David Smeltzer provides brief overview of proposal) We have uh David Smeltzer with
the PUC staff here. Um David, would you provide a brief
overview of this proposal for publication? I sure will
Hi David Smeltzer Commission staff. (item:6:David Smeltzer call rulemaking slightly overdue, cites HB1484) This is rule making
is a little bit overdue. It's one of the boxes that
we need to check from HB1484 from the 87 legislation
And I think this is a really important rule making
for us to get underway in short. It allows for in water
transactions. It allows for an acquiring utility to
apply the rates from one of their preexisting and approved
tariffs to the acquired utility in sort of sale, transformer
transactions. This is important because it allows water
systems to begin getting recovery at higher rates sooner
so that they can implement changes and it should facilitate
more transactions in the water space. Um The, the the
nomenclature of the of the rule is that it would allow
them to apply authorized acquisition rates. Um And
there are a number of requirements that are involved
with this rule making including the submission of a
capital improvement plan based on discussions that
we've had. I think that staff is going to recommend
one change to the proposal for publication from what
is filed. And that is out of recognition of the fact
that sale transfer merger proceedings are also CCN
proceedings. The there is a statutory requirement for
a capital improvement plan as part of all water CCN
proceedings. And so this draft as a capital improvement
plan if available. And because of the statutory requirement
with regard to CCN S, we would modify the proposed
order by striking that if available. And just for the
proposal stage, we would require a capital improvement
plan. And so we would look for commission action on
this to adopt this proposal publication with that modification
Any thoughts on this one that seems consistent with
what you just uh alluded to madam chair. It's pure
coincidence.
(item:6:Motion to adopt proposal for publication) I would move to adopt the proposal for publication
with the proposed change that staff has provided. I
have a motion in a second all in favor. Say I I
motion passes
(item:7:Review of 16 TAC § 24.101 – Water Rate Appeals - Proposal for Adoption) next up is item number seven project number 54932.
This is the commission's rule making regarding its
review of 16 Texas administrative code 24.11 water
rate appeals, Sheila, do we have anyone from the public
signed up to speak on item number seven?
Uh David, would you please please provide a brief overview
of staff's recommendation? (item:7:Iliana De La Fuente lays out Project No. 54932 – Review of 16 TAC § 24.101) Iliana De La Fuente from our division
is gonna play this out. Ok. Um Hi Ian de from commission
staff. Um So this rule making uh implements Senate
Bill 3 87 and House Bill 36 89 amendments to Texas
water code 13.0 43. And these amendments uh essentially
reflect the commission's appellate authority uh to
allow ratepayers to appeal an increase in an mou uh
water or sewer, uh rate case including a rate increase
resulting from a decision by a governing body of a
municipality. So it just clarifies um, our appellate
authority and we just ask that y'all adopt the rule
as amended. You have any thoughts on this one or? Yeah
I agree with it. (item:7:Movement to adopt proposal for publication) I would have, I would move to uh
adopt a proposal for um application.
You would move to approve stance recommendation. So
I have a motion and a second all in favor say I
I motion passes.
I don't have anything on it. Sorry just I don't know
if Sheila needs this. Well, he said for publication
but we meant adoption. No, II I moved to what she said
So
I was listening.
Ok, I don't have anything on items eight or nine unless
y'all do the next two items. Items 10 and 11 will be
taken up together. Sheila, will you please lay out
these items? Yes, ma'am. (item:10:Shelah Cisneros lays out Compliance Filing for Docket No 52321) Item 10 is docket number 52709
The compliance filing for docket number 52321, which
was the application of ERCOT for a debt obligation
order persuant PURA Chapter 39 step chapter M as in Mary
and (item:11:Shelah Cisneros lays out Compliance Filing for Docket No. 52322) item number 11 is docket number 52710. The compliance
filing for Docket number 52322. That was the application
of ERCOT for a debt obligation order. Pursuant to PURA
Chapter 39 subchapter, N as in Nancy. (item:10:Memo from commission staff requesting guidance) Before you is
um a memo from commission staff requesting guidance
on from the commission on certain issues and that was
filed in docket number 52710. Ok. Any thoughts on these
(item:10:Commissioner McAdams call for creation of separate docket) I I do uh madam chair. Um Basic situation is securitization
continues to be a complex process that raises novel
issues for the commission to consider. And I'm sure
our market participants want clear guidance from the
commission. However, I believe we need to instruct
staff to file a petition for a declaratory order in
a separate document docket. In this instance, this
compliance docket is not an appropriate home for addressing
the issues in question. Um We need somewhere to build
a record on the issues and if necessary get briefing
from market participants. Therefore, uh pending any
discussion, I I would move that we direct staff to
file a petition for a declaratory order in a separate
docket. (item:10:Motion to adopt proposal) We have motion. Do we have a second motion
in a second? Uh All in favor of say I I motion
passes. That's for items 10 and 11. Correct? Yes,
(item:12:Shelah Cisneros lays out SOAH Docket No. 473-22-2464 – Application) Next up is item number 12, Sheila, will you please
lay out this item? Yes, ma'am. Number number 12 is
52728. This is the application of the city of College
Station to change rates for a wholesale transmission
service. The commission previously considered this
docket at the January 26th of meeting and the commission
remanded the docket to SOAH for further processing
before you know, is a so a proposal for a decision
that was filed on July 27th, we had three parties that
filed exceptions to the proposal for decision College
Station, Tiec and Commission staff. The so AJ has filed
a memo uh making one correction to the proposal for
decision. We have uh a memo filed in the docket from
the Commissioner McAdams. We also uh have oral argument
that was requested in the docket and the commission
voted to grant oral argument.
Sheila, could you please call up the parties um individually
for oral argument. Each party will have three minutes
to speak. Yes, ma'am. (item:12:Oral argument from Thomas Brocato, City of College Station) The first person of the first
party that decided to speak. I believe, sorry, we have
individuals but not uh party names, but I believe it's
going to be a college station.
Good morning commissioners, Thomas on behalf of the
city of College Station before I begin with my time
If um with your indulgence, um if I could just introduce
um some elected officials who joined me today and then
I'll turn it over to the mayor and the city manager
to um make the, the comments.
Uh then um if I May today, we've got council member
uh Mr Bob Yancey, council member, Elizabeth Coa council
member Dennis Maloney, council member, Mark Smith and
council member, William Wright. Uh We've also got the
mayor, um John Nichols and then the city manager, um
Brian Woods. Um So I'll turn it over to them to uh
make the comments
before I begin and I may have missed it chairman. And
if I did my apologies, but did you set a time limit
for all, for all argument? Three minutes, three minutes
for each person?
Uh Thank you Commission. As Thomas said, I'm Brian
Woods, I'm the city Manager of College Station. I'm
hoping I will only use one of your minutes. Um uh First
I just want to thank you for granting us the oral arguments
And also, uh we read the memo from Commissioner McAdams
and obviously support the sentiment there. Um So I
only want to get a few things out and, um, we, we
see where the goes. I just want to emphasize that the
city of College Station and College Station utilities
is always trying to do what's right in these scenarios
And I believe we did from the beginning and obviously
this is, goes back long before my tenure, your tenure
or a lot of the staff, everything we did in the interim
filings. I know you guys have seen it was written in
the direction of staff and other commissions
which we all we all performed in good faith. So when
we got to this place, um and obviously, we still feel
like we did the right thing we did in good faith, negotiate
with staff, we came to a settlement, the staff recommended
and had no objection by the T I. Obviously, since then
there's been some other things that have transpired
but we do feel appreciative of the process. And again
the commissioner's memo because we feel like if that
process plays out that we'll get to the right answer
And I think that's what we all want.
So I'll conclude by just saying that we're supportive
if the commission wants to send that back to the administrative
judge to get a ruling there and we will withhold any
final discussion until that point. And then we'll just
ask finally of consideration of the fact that while
we definitely want this to be done, right? And we're
willing to wait additional time. Um, we have, uh, been
going through the process for two years, which also
has an impact to our customers, but I appreciate very
much the time and, and everything you all have done
to this point and I will turn it over to the mayor
and thank you very much. Uh I appreciate the opportunity
to speak as well. Uh Our city manager covered most
of the relevant points and a law judges, uh procedural
documents certainly document that we have complied
with PUC staff and commission uh guidance uh throughout
the entire time we filed these interim filings. Uh
I would just add that the City College Station really
does find itself in a difficult situation. As you know
we're a very fast growing city. We host the nation's
largest public university. We have a lot of people
moving in and out of the city, uh uh in, in, uh
and we manage it in a, in a way that we think
is uh providing great services and a great community
to live in. Uh We do not believe that it is really
fair to be financially penalized for following the
explicit directions of pe C staff and commission over
this period of time. Ultimately, the cost of this settlement
we paid for by the ratepayers of college station electric
utilities. Uh We agree with the sentiments in Commissioner
McAdams memo and as the city manager said, uh would
you deem inappropriate to remand this? We will present
our case at that time. Thank you very much. Thank you
Thank you, commissioners. I appreciate y'all being
here and all of the folks that came to support you
Commissioner McAdams, you filed a memo. Could you please
land? Oh, chairman, sorry. Before you start, we have
one more party that sign up to speak. I'm sorry. That's
all right. Commission staff signed up to speak.
It does.
Good morning chairman and commissioners. Um Mildred
and Alley for commission staff and for commission staff
We just want to reiterate that staff has um contemplated
all the issues um laid out in this docket. Um We believe
that we in our briefs, our initial brief, as well as
our reply brief. We, you know, we consider the mitigating
factors and we stand by our recommendation that was
presented to the ALJs. Thank you.
All right, no other party signed up to speak.
(item:12:Commissioner McAdams lays out memo) Uh Commissioner McAdams. Could you please lay out your
memo? Absolutely madam chair. Thank you. Um I follow
this memo because I think the ALJs in this situation
uh may have run a bit too far with our order on
remand. Um And I think that's a key distinction in
terms of the process. Um An order on remand is an interim
order, uh not a final order. And if the SOAH LJ thought
that we had made a final decision, then they misunderstood
the nature of the interim order. Um and our discussion
at the January 26th open meeting. Um I, I think it's
important that we are not prejudging uh what we are
referring to SOAH to solve for us, we need so a process
to bring forward the relevant arguments and facts so
that we can uh incorporate, incorporate those facts
in our ultimate deliberation on a final order. Um as
such, I believe that we should the PFD in this instance
and rescind our remand order of January 26 2023 this
should be remanded to. So with clear instruction that
we had not reached a final decision on any contested
issues while continuing to reject the proposed settlement
Therefore pinning any feedback. I certainly have a
motion and would move that we reject the PFD rescind
our previous remand order and remand us to SOAH consistent
with my memo and our ultimate discussion. You have
any discussion on this. I, (item:12:Commissioner Glotfelty in support of memo) I agree with Commissioner
McAdams in the memo and uh I think that that's the
most expeditious way forward and, uh, I am fully prepared
to support it and would second the motion if, if agreed
to. (item:12:Motion on item) Ok, we have a motion and a second. Uh, all in
favor say I I motion passes
come
items. 13, 14, 15, 16 and 17 were consented. (item:18:Joint Application of Bluebonnet Electric Cooperative, Inc. and LCRA) Next up
is item number 18, Sheila, will you please lay out
this item? Yes, ma'am. Item is stuck at number 54849
This is the joint application of Blue Bon Electric
Coop and LCR A transmission services to transfer CCN
rights in Burleson County. Before you use a proposed
order, Blue Bonnet and LCR A jointly filed corrections
The A LJ filed a memo revising the proposed order.
(item:18:Commissioner Glotfelty lays out memo) And Commissioner Glotfelty filed a memo in this Dockett
Will you please lay out your memo? Absolutely, uh,
commissioners, um, the law, um PURA requires that any
purchase assignment or lease, um, requires that the
commission determine that the purchaser assignee or
less he can provide adequate service, which I think
is missing in this order, the revised proposed order
should be modified to indicate as in my memo that the
order includes a statutory determination and findings
of fact supporting that determination. Therefore, I
move that the revised proposed order. I move to support
the revised proposal order as modified by my memo which
clearly lays out that LCR A is the purchaser assigning
a lessee and that they do have the the
ability to provide adequate service under this order
and under our law and rules
muffled. (item:18:Motion on joint application) I I would support that in a second, uh, pending
in thoughts from the other end of the day. Ok. Ok.
We have a motion in second, all in favor. Say I I
motion passes (item:19:Application of South Texas Electric Cooperative, Inc. to Amend) next up is item number 19. Uh Sheila
will you please lay out this item? Yes, item 19 is
second at number 54936. This is the application of
South Texas Electric co-op to amend it CCN for San
Miguel de Cruz double circuit 3 45 KV transmission
line. Before you use a proposed order that addresses
an unopposed agreement between the parties, stack,
filed corrections and exceptions to the proposed order
The ALJ filed a memo revising the proposed order. A
commission council memo is filed, recommending changes
to the proposed order and Commissioner McAdams filed
a memo in this docket. (item:19:Commissioner McAdams lays out memo) Commissioner McAdams, would
you please lay out your memo? Yes, ma'am. Um, members
I filed a memo in the dock in an attempt to get
a little clarity on this agreement and to address some
potential safety concerns uh that have arisen through
the process. There are plenty of reasons in my view
to oppose this settlement. However, this is a critical
line. This is important to the state and to the ERCOT
system. Um There are a number of affected habitable
structures among them, but I think we can productively
at this stage, talk this out and I would ask, uh as
a part of my layout, can staff uh begin approaching
as well as
I grudge for commission staff? Ok, I appreciate you
humoring me on us. Of course,
I can just go if you be
while they form ranks right. Musical chairs. Good morning
commissioners. I'm Jennifer Littlefield with stack
and with me is Corey Allen, the Director of Power Delivery
Great. Um I've also asked staff to have representatives
from the uh National Guard Bureau and the Department
of the Navy. Um And I believe that staff has them on
the phone. Uh Do we need a moment to get that set
up, please? I'll, I'll give him a call right now, Greg
So I'm gonna call Jamie Flanders first from the National
Air Air National Guard
and you'll hold it once you begin, hold it as close
to the microphone as you can for the core reporter
Good morning, sir. This is Pat. Good morning, Pat.
Uh This is I grudge, uh calling from the PUC. I'm sorry
it was called Pat first. Hold on just a moment. I don't
think she can hear it. Can you turn the volume up at
all or maybe speaker speaker? Ok. Go, can you introduce
yourself, please? Pat
Hi. Can you hear me? Yes. Can, can you hear me? Yes
hello? It's like we're having, uh, can you please introduce
yourself?
I think we're having a connection issue, of course
Mhm.
I try calling again. Excuse me? I understand this is
awkward. Uh It it will be productive. Um
Unfortunately, I get only two bars in here. Of course
Yes, I can hear you.
Hold on just a moment. I think the court is still part
of your.
Hello, Mr Powers. Yes, sir. Yeah, go ahead. Can you
please introduce yourself? Yes, I'm Patrick Powers
I am the uh Navy Region Southeast Deputy Mission Sustainment
Officer and Navy Region Southeast is the uh the headquarters
that owns all the installations and equities for Navy
in Southeast, from Texas to Guantanamo Bay. Ok, perfect
Um So let me continue through my layout and then I'm
gonna ask Mr Powers some questions. Um And then are
we going to merge in uh National Guard? Yeah, go ahead
and merge in National Guard and we'll have them identify
themselves before they speak for confirmation for the
recorder. If you can hold on one second please, Mr
Powers.
Sorry, this is out of the ordinary everybody, but this
is a reliability line. We're going to make this happen
No, we appreciate um the attention and wanna make sure
we get it right. It would be helpful for him to be
closer to him. Hello? This is Jamie. Hi, Mr Flanders
This is Ian Gretch from the puc of Texas.
Hi. I'm gonna merge you with a call uh with Mr Powers
Ok.
Right. So before each person speaks, it's gonna be
hard for the court reporter to distinguish which person
is speaking whenever they speak. If they could just
say their name first, that would be helpful. Did you
all hear that? Yes. OK. Thank you. OK. (item:19:Representatives of US Navy, Texas Air National Guard testify by phone) We now have
Mr uh Patrick Powers and Jamie Flanders on the phone
as I understand it. So, gentlemen, I, I'll have some
questions for you both. But at the start, let me say
it, the purpose of my memo was that I was, I was
uh concerned that stacks opposition to your, with your
with stack's opposition to your motions to intervene
Uh I believe the safety concerns highlighted after
the fact warrant further discussion trying to bring
forward how to ultimately resolve uh any safety concerns
Um And I hope that ST e would take the safety of
the pilots and certainly the communities in that surrounding
area into uh into consideration as we try to find mitigation
strategies in a path forward. Um Now, I can't say ultimately
how I would necessarily vote on such a motion, but
I would be very interested to see the Navy and National
Guards, um uh how they felt um And whether they need
to file or would be interested in filing new motions
for intervention with requests for good cause exception
for lateness. Um And what we might do in that situation
And so, uh but the process might not be necessary and
that process might not be necessary depending on how
the conversation goes today. And that's why you gentlemen
are on the phone. So as it relates to uh Mr Powers
in the Department of the Navy. Um First sir, are there
any segments in the settlement route that you are concerned
with?
Was that what the, are you speaking about the original
route, sir? Or the alternate route that was passed
a couple of months ago, the CCPS dash X alternate route
that's correct, better known as route X and that is
the alternate route that was passed uh recently. Yes
Um the, the Navy is good, sir with the C CBS X
route hot dog. That's good. Ok, and you're good with
the, the line height, right? Yes, sir. Ok, good to
go. Um And this may be short us National Guard. Uh
Mr Flanders, same question to you by the airspace manager
for the uh Air National Guard, representing at this
point, the Texas Air National Guard, specifically the
1 49th Fighter Wing out of Kelly Field. Uh That was
a very long statement to do exactly what Mr Power said
we have reviewed the X route and we concur with the
proposal as written, there will be minimal impacts
to our training mission. However, we can mitigate those
And as long as you remain away from mcmullin Range
we have no further concerns over.
Ok. Good to go. Well, Adam, can we clarify the height
of the Mr Mr Flanders as proposed? And what's before
the commission is a, is a uh 175 ft uh 3 45
kalt transmission tower. Um And that is ok for your
uh training purposes. That's a question to us, sir
Ok. Um Actually, if I may indulge the commission's
time for just a quick history lesson. Military training
routes have existed since the 19 fifties and sixties
They were created uh as part of the Cold War to um
to basically go against the Soviet Union and train
in an ability to go down low and stay low, go below
enemy radar, strike a target and return home safely
That was our military doctrine from the 19 fifties
all the way up to through the 19 eighties. If you remember
during that time, uh we saw the fall of the Soviet
Union, we saw the emergence of stealth technology and
smart bombs. And when that happened, our military doctrine
did it um uh a complete paradigm shift. We went from
going low and staying low into uh we need to be as
high as possible and far away as possible in order
to survive an engagement with our uh asymmetrical enemy
at that time. In addition, also, remember this is the
early 19 nineties and going into the early two thousands
what was going on in Texas? At that time, you had,
you saw in a massive suburban strong occur as such
in construction and other activities were occurring
underneath our legacy, military training routes because
of our military doctrine, we actually did not object
And so we have seen extensive encroachment upon our
military, but now we have reached a kind of a new age
and we have done another paradigm shift. We are now
facing a peer and near peer, adversaries who have technological
capabilities that are equal to us and staying within
unclassified realm. I can say that they have in some
cases surpassed us. In that case, we have to go back
to survive and to do that, we have to go to physics
curvature of the earth and the and, and training. And
so we have to go back down low and stay low in
order to avoid detection in order to strike our target
Unfortunately, now we are seeing all of our legacy
military training routes have encroachment and they
have things going on and construction going on. So
that's a very long story. I'm telling you that I apologize
for the long story. But what I want to say is this
in addition to this, we also are fully aware of what
happened in 2020 2021 with the uh Texas Power System
we fully support um the revitalization and the expansion
that needs to occur within the uh the uh Texas public
utilities. So the Texas Air National Guard, when we
see this encroachment, you know, these powers and these
these lines, it will impact us, but we do mitigate
it and we will do our best to uh accept what we
can in order to allow the continued expansion of the
U the Texas power system. So again, a very long story
but the fact is I can't tell you that this won't impact
us. The fact is this will impact us and the only option
to not impact this is to not build and that is not
acceptable to us. So we would prefer to go with the
X route. We can dedicate the strategies. We will, we
will accept the impacts as much as possible. Thank
you very much over. OK, way to go.
OK. And, and, and for both parties, we, we have to
take a, a frankly a narrow view, but this, this line
is gonna be there for a long time. And um we, we
only have so many opportunities to get this right and
on the front end, that's when you try to get this as
right as possible. And I wanna make sure that the Department
of the Navy and the US National Guard Bureau are um
are not going to oppose this route uh or object to
it in future proceedings if at all possible because
again, this is a reliability project. And so what I'm
hearing from you both is that is, in fact the case
Jamie Flander from the National Guard concurs, we will
not approve, we have no plans to further object to
this project.
Great Navy
lawyers are thinking
you want a letter Mr Power, are you still on there
Must
Oh, yes, I am. Can you hear me? Yes, sir. Ok. Yes
From, from the Navy pat powers. Um We have no objection
to the X route. We have evaluated and found it compatible
with training and operations of the Navy. Ok. That's
what I needed. I'm good. Ok, you're good. Ok. So I
was just asking Richer McAdams if you thought a letter
um filed in the in the docket would be helpful that
states exactly what the two gentlemen have said on
the phone. Um even though it won't be evidence because
it actually might be because my fear is we approved
this and then all of a sudden us Naval Air Station
Corpus Christi has a brack proceeding one day and this
comes up in terms of the viability of the installation
So from the state of Texas point of view, that's Belton
suspender security for us.
So, uh I would ask for a letter from the Department
of the Navy and the US National Guard Bureau and that
would help us um moving forward. Is that possible?
Gentlemen?
And you want the letter to state, what sir, that, that
you are unopposed to route X and, and, uh, how it is
proposed in the, uh, um, in the final order and we
take no further. And yes, sir, we can, we can provide
that. Um, what, who, who would you like it sent to
sir? If we, if we could have that filed in, uh, docket
54936,
the State of Texas would be very grateful.
Yes, sir. Yes, sir. From the Navy and Commissioner
I'll jump in one other option perhaps to facilitate
that. If they, if it's easier, they may be able to
provide the letter to stack and ST could file it on
their behalf. And, and, and that is absolutely, that
may be easier if you could provide that to South Texas
Electric Cooperative, they could file that on your
behalf. And that way you don't have to go through any
logistical wranglings of making a filing at the PUC
Right. Just ask if you could ask stat to work with
them to get that file, that'll work, staff, work with
them, make this happen
uh, before the 28th.
And you want two letters, I would like a letter from
the Department of the Navy and US National Guard Bureau
before, uh, and before and filed before sep the September
28th open meeting.
Sure,
serious.
Are you still there? Yes, we are. Uh, this uh we, we
we, we can maybe can, can make that happen. Could you
just, would you do me a favor and, and call me offline
and uh, and give you where you want this to go? Absolutely
I'll follow up with you.
Ok. Great. I'm good, Lori Jimmy, I'm gonna hand this
back to you. You're at the transmission people and
then just to clarify is it, is an all commission staff
ends the phone call from my perspective. Yes. Yes.
Thank you, sir. I'll follow up with you after this
(item:19:Commissioner Cobos comments on proceeding) Commissioner McAdams. Thank you for your extra detail
and, and work on this. I after reviewing the documents
filed in, in this case as well, I thought it would
be appropriate out of due diligence to ensure that
we had the, you know, us National Guard and Navy on
board because we don't want this line to ultimately
get any barriers later down the road. It is a very
important line. It's one of several lines that's part
of the broader Rio Grand Valley project that ERCOT
identified as critical for liability. So we want to
keep this project overall project on track, but at
the same time, we got to make sure that everything's
buttoned up and ready to go and I appreciate your extra
steps in making sure that we get that documentation
from the Navy and the National Guard.
(item:19:Commissioner Glotfelty comments on proceeding) Uh I, I too, I was kind of excited to see this
uh how this worked out and you did a good job. Uh
um, uh, talk about an audible that worked it. Uh, it
was pretty good.
I'm prepared to support route X. I think that with
the discussions and the commitments, I think that's
great. I did, I was prepared to have a discussion about
the specifics, line segments. The Navy and the International
Guard were only opposed to 10 of the 26 segments. And
you know, I think it's, I think we've reached a conclusion
there. I might add that, that these routes and the
Navy and the International Guards training was a to
the two
to the Dixie Airfield and the Yankee Yankee. I think
they're called ranges anyway, as I was growing up and
after college, I used to go hunting at a ranch outside
of Tilden and we used to stay up till all hours of
the morning, waiting for the jets to fly by to bomb
these bombing ranges. So it was always exciting to
watch. But I'm glad they've come to the table and allowed
this important route that Commissioner Cobos has spearheaded
That is truly a reliability problem. It's truly a challenge
and I'm appreciative that the landowners, these are
big pieces of property in South Texas. These are, we
we, we gotta come together and solve Texas's problems
and I'm glad that they, so I'm I'm supportive of this
route in this effort as am III I support moving this
along. Let's get the line built but appreciate the
time and effort to recover this latest document from
federal agencies. That way it gives, gives us a little
more certainty and a little more protection in the
future depending on the growth patterns of South Texas
So, so do you want to delay the final approval until
we get the two letters at the next meeting or do you
think we can approve this? And uh, ah, I look to Loria
I'm kind of looking to you, wait for the letters and
then approve it at the 28 deposit. Ok. I'm fine with
that. As am I? All right. (item:19:Shelah Cisneros states item will be scheduled for Sept 20 meeting) We'll plan to bring this
back to the September 20th of a meeting. Ok. Very good
Excellent. Thank you. I'm doing great work on everyone's
everyone's part. Ok. Items 2021 were consented (item:22:Complaint of Shareef Abdullah Against Reliant Energy) next
up is item number 22 Sheila, will you please lay out
this item? Yes, ma'am. Item 22 is stuck at number 55150
The complaint of Sharif Abdullah against reliant energy
before you use the proposal for a decision that was
filed August 7. There were no corrections or exceptions
filed by the parties. (item:22:Chairwoman Jackson explains proposal for decision) The proposal for a decision recommends
that the complaint against reliance be dismissed for
failure to state a claim for which relief can be granted
However, because reliance switched the complaintant
to his desired plan and waived the early termination
fee. Dismissal for moness is more appropriate. Therefore
I recommend that the commission changed the grounds
for dismissal from failure to state a claim for which
relief can be granted to t and modified the proposal
for decisions accordingly. Any thoughts? (item:22:Commissioner McAdams expresses support for motion) That sounds
like a great motion madam chair, I support it. (item:22:Chairwoman Jackson moves to modify proposal consistent with discussion) I would
move to modify the proposal for decision consistent
with our discussion. Um Do I have a 2nd 2nd? All in
favor. Say I I motion passes (item:23:Application of Southwestern Electric Power Company) next up is item number
23 Sheila, will you please lay out this item? Yes.
Item 23 is docket number 55155. This is the Reman docket
of docket number 40443. This is a reminder. Commissioner
Cobos has recused herself from this item before you
is an appeal of order. Number two filed by swept co
Any thoughts (item:23:Commissioner McAdams describes commission approach) I do? Uh Yes, ma'am. Um
It, it appears that swe co is under the mistaken belief
in my opinion that the commission has, the uniform
has a uniform method for processing dockets that are
remanded from judicial courts for further processing
We do not. Um Instead the method for processing is
determined by an individual, by the individual complexity
of a docket and a specific remedy ordered by the courts
In this case. I agree with the commission A LJ that
the commission held pre hearing conference is unnecessary
and therefore, I would move to deny appeal of order
number two
and Lori can't talk. What do you think, Jim? (item:23:Commissioner Glotfelty shares agreement with McAdams) I'm for
it. I'm, I'm in agreement with you. (item:23:Chairwoman Jackson supports ALJ decision) I also believe
the AL OG guy. Right. So we have a motion by Commissioner
Adams. We have a second by Commissioner Glotfelty.
All in favor. Say I I motion passes.
Item number 24 was consented. I don't have anything
on item 25 and 26. And unless y'all do, I don't have
anything for item 27. (item:28:CY 2023 Reports of the Electric Reliability Council of Texas) So next up is item number 28
project number 54444, calendar year, 2023 reports of
the Electric Reliability Council of Texas. Specifically
we will be discussing the report that ERCOT filed regarding
the energy emergency alert condition that affected
the ERCOT system on September 6, Shelah. Do we have
anyone from the public signed up to speak on item number
28? No, ma'am. No one signed up to speak on this item
I believe Woody with ERCOT is here.
Ok. Would you please come up and provide an update
regarding uh the ee a condition as well as a recap
on the recent conservation appeals?
(item:28:Woody Rickerson of ERCOT offers update) Woody Rickerson with ERCOT
so on September 6th, approximately 7:10 p.m. until
approximately 7:25 p.m. are quite observed at decline
in system frequency from 60 yards down to 59.77
in order to access additional reserves to restore and
maintain frequency, er got declared an EE a 27 25 due
to the tight reserve margins. That evening, ERCOT had
already deployed
Nonspin ecrsrsffr. We've also deployed er S and we
requested that transmission operators implement their
distribution voltage reduction measures at that point
As part of the EE A two declaration ERCOT requested
the deployment of Load management program capacity
So E A two allowed us to quickly access loaded resources
which were deployed through RRS S sponsor reserve to
stop the frequency decay. It's 7 37 system frequency
was restored to 60 Hertz. No additional measures were
required at 8 27 we went from EE A two to E
A one. Then 8 37 system exited the EE A one and
went back to normal conditions.
So that's a summary of the EE A event. Now, we're in
the process of doing a more forensic analysis of all
the procedures. All the steps
investigating the PR C, the physical responsive capability
number,
the physical responsive capability number, the PR C
which drives a lot of, most of our, of our procedures
showed, I think 2104 megawatts while frequency was
declining. So we suspect that that Pr C number was
not accurate
and we're looking for why they may not have been accurate
There are several possible reasons, but we'll wait
and see what that report says. We speculate on what
caused that. But that's a, that's a summary of what
happened on September 6th.
It was a uh
at the time it was a September peak, a new September
peak,
of course, I think we broke it again the next day.
Um, we had relatively low wind that day.
We had a con congestion problem that caused us to need
to curtail some generation.
And we have this all occurred right in the middle of
a solar down. So we had about, I think it was 1500
megawatts of solar left over. So all these things were
moving at the same time and wind at that point was
about 5000 megawatts kind of stagnant. It wasn't increasing
a lot, a lot of the evenings at this point, we'll see
wind have started ramping up, but at this point, it
hadn't ramped up.
So the operations team had a, uh, had kind of a balancing
they had to do, they had to protect system equipment
to keep it from being overloaded, which required moving
generation, decreasing generation. At the same time
we had solar falling and we needed to, to have generation
And so there was a balancing act to keep out of Load
shed, but also protect the system equipment. I think
the operations team did a really good job. Very unusual
circumstances. It's not something you see every day
but they were able to balance the two things and maintain
reliability.
(item:28:Chairwoman Jackson asks about skipping EEA Level One) So one of the things that I guess have has been pointed
out is that, you know, we kind of never went into ee
a one, we went, we went straight to EE A two and
um, oftentimes you think of an E A event and you think
of it more in terms of loader generation and you don't
always, you know, think about it, it also can be caused
by frequency. So, I mean, can you talk a little bit
about, you know, kind of both of those things, you
know, the need to go straight to EE A two and then
also the, the, the frequency concern. Yes. So there's
two. if you think about the ee a process going from
a watch to E A one, A two A three, there are
two different two different paths that you can take
One path is strictly based on reserves as reserves
decline from one point to another, you go from E A
1 to 2 to 3 and then eventually into Load shift if
you, if you have to, but there's also a frequency path
And so we were watching PR C decline when the frequency
overrode the knee and the fastest way to get more reserves
on the system was to go straight into E A two.
So it wasn't because, I mean, there was some speculation
that it was because of a thermal unit trip or something
like that. And that wasn't the case at all. Um Like
I said, the, the PRC indicated that we shouldn't have
seen that decline. So we need to investigate and that's
what this analysis right now is. What were people reporting
in their PR C numbers? And where is, where, where is
the, uh, where is that discrepancy? What, what was
that? And so that is one of the things that's being
looked at right now and we may have changes in and
uh, how PR C is reported.
So, in your investigative process, when you go back
and you look at PR C, do you look at specific sources
and if you find something, do you have a process where
you actually go out and look at the broader group as
well? Yeah, we'll look at individual units, we'll probably
have some RFIS. Um Our PR C is dependent on what people
report to us as our high sustainability limit in part
Uh It's also dependent on state of charge from batteries
Uh We also need to investigate how the high dispatch
limit was affected by units that were curtailed. Uh
So all those things need to be looked at. Um But with
that level of PR C, we were watching frequency decrease
proportionally to what the solar down ramp was basically
So there was no headroom left.
And so in order to find some head room, we went into
E A two, deploy the Load of resources, which if you
think of generation and Load being balanced that provided
generation a chance to move back down and provide more
headroom and some frequency response.
Go ahead. Yeah. Um (item:28:Commissioner Glotfelty reflects on expected emergency actions) Woody, I appreciate uh I appreciate
the efforts. I know y'all are supposed to have 24 hours
and uh we gave you more. Uh I look forward to the
more forensic analysis. Um I think there's uh uh a
lot more to look under the here. Um To me, um I
just uh first of all, I wanna say, um this is in
no way a operator issue operators primary requirement
as you know, is to save the transmission system. I
go back to the 2003 blackout. We back then operators
were told if you shed Load, you get fired. We don't
want that. We want them to take the actions that are
necessary to save the system. The least expeditious
and least costly way to get that system back into balance
most expeditious way. I'm sorry, most expeditious way
to get that system back into balance. Thank you, sir
Um And so I, I'm appreciative of the operators and
um uh what they did for the system that day, I think
there are issues that still need to be looked at. I
think in your next report, I hope we can have a better
discussion on the thermal outages in the north of the
state and around the state as to what that impact was
And was there a uh were they all forced outages? Um
Are they um because clearly the lack of generation
in the north was what drove part of this, this issue
or at least the contingency, the other area where I
would love for you all to explore is the line ratings
in the south that the lines that were curtailed. Pablo
had told me that those lines were dynamically rated
and that we allowed 101 130% of their rating effectively
based upon that dynamic line rating. The question is
are they rated correctly? And this is a process by
which the TD us are the ones who under n rules provide
you all with the ratings of the line. And I just want
to make sure that you all have the ability and if not
maybe we need to get the Texas re involved or involved
to ensure that those ratings are correct all requirements
under guidelines. So I just hope that when you come
back, it may not be in two weeks, it may be longer
than that, that we have those data points that we can
look at to ensure that these situations don't happen
Again. I think it's strange when you have an operator
who puts yourself into ee A too. Um, but, uh, I think
that was the uniqueness of this day. Um, and obviously
ee A two was a solution that they thought was best
And, and I don't think we can question that. I think
what we can do is question the, the system around there
to make sure that if we get into this situation again
we, you all the operators understand what's the best
action to take. Was this the best action not determining
whether this was good, bad or ugly, it happened, it
saved the system fine. Is that the appropriate action
to take going forward if we see these similar conditions
and I look forward to working with you on that. I do
want to say one final thing and that is that
when we spoke, um, you know, I think there is a big
discussion that's missing on the thermal outages in
the north. I was remiss that this letter that was sent
to us didn't talk about them at all, but from conversations
that I've had with uh with you all uh at ERCOT, um
that was one of the reasons why this transmission line
became overloaded or was in a contingency issue. Um
And just hashing that out would give me a little bit
more comfort to understand that. So we'll make sure
that the analysis includes a look at where the outages
the uh generation outages were. And so, so you will
beef up uh an explanation of the, the words limitations
on other generations. OK. That would be appreciated
And, and, and then I guess the one other thing is um
iiii I spoke with Dan yesterday. He doesn't seem to
think that there were any um n violations. I just would
love for you all to go through uh the, the guy, the
uh uh um uh event reporting that you all are required
to under our guidelines and rules to submit information
to them. And if there are areas where you think there
might have been a you were within your guidelines but
or within your procedures, but they don't seem logical
to, to uh point point those in the next filing as well
Yeah, we always look at these type of operation in
as opportunities places to sharpen our tools and improve
our procedures. So that will be part of that analysis
as well. There are some things we can change the procedures
to make these things
more road for the operators. Then we'll do that. Um
We are going through a phase where we, our grid is
not the grid we had in the past and we're going to
have new challenges and these new challenges are a
part of having different kinds of resources that behave
in different ways. And so our, our procedures and processes
will need constant tune ups to keep up with the changing
grid. And so we'll make sure we do that. Can I just
say one more thing? And this is to address madam chairman
and the commissioners. And that is to me, my gut tells
me that part of the challenges was um
deploying Ancillary services in a order that was not
normal for operations or in a, in a reactionary way
to deploy different buckets of Ancillary services.
To me, this goes back to Senate Bill three from two
sessions ago that we should be conducting an Ancillary
service study section 14. Um And we really need to
do that. Um And I look forward to working with you
all to figure out how we could get that done to provide
the market with some assurance and understanding of
how these products are being deployed on a real time
basis. Thank you. Uh (item:28:Commissioner McAdams reflects on details of recent grid event) So, so I'd like to point out one
thing. Um I'm not, I'm not trying to oversimplify the
situation that I think we all are facing. Woody's team
at ERCOT and, and the commission is that there are
only two grids on the planet that are ahead of us in
terms of uh managing a more diverse resource mix. Um
And that means a higher penetration of uh renewable
or variable intermittent resources. And that's California
Iso in Australia, both systems have a higher degree
of command and control over their system. We depend
on market forces uh to drive a lot of activity and
behavior on our grid. I think what you'd acknowledge
that. Um OK. Um And as a result, it's more challenging
for the operator to know what to expect from second
to second moment to moment. And I, I think we, we saw
a little bit of that on uh on the day in question
Um Woody, if I could, I'd like to go through um You
mentioned energy flow out of South Texas uh out of
the South increased the loading on a significant 3
45 KV transmission line beyond the line's post contingency
limit. Now I sort of at the Resource Aqua summit I
attended last week that Dan was at um I assured the
press and a F commissioner and the NR CEO that we would
have a debrief this week to kind of uh have an initial
uh breakout of what happened. That's a, that's a significant
sentence right there on what was happening real time
on the Wednesday afternoon or evening. So this 3 45
KB, is it a double circuit line? So this is a contingency
overload, correct? But is that line? In fact a double
circuit, the contingency was the overloaded line would
be a single circuit. Yeah. So my question is under
N standards doesn't. Um And, and this is where I'm
trying to, I'm not an engineer trying to figure out
what exactly the standard is for that line. I know
that you are accounting for the single uh single circuit
contingency that has been reported to you for your
modeling purposes by the transmission and distribution
system operator, correct? But if it's a double circuit
system under uh under NT guidelines, there's two con
they, they can have two contingency factors, correct
OK. So I just wanna make sure that that technical capability
is accounted for and that we don't, we don't see an
overload when in fact, it's not going to happen.
I'm gonna have to ask you to restate that I don't quite
follow you. Well, um again, your actions, your operator
actions were based on that contingency level. Correct
All right. So that's a, an energy threshold that they
believe will be reached and overwhelmed and therefore
emergency action is necessary based on that emergency
threshold. Ok. And what I'm saying is, was there more
uh capability that could have been, was there more
capability on that line than you were? In fact, accounting
for because of the reporting of the TT sp to you on
the rated capabilities of that piece of equipment.
So there are many factors that go into the rating of
a line. Um, there are clearance factors, there's the
age of the line, the type of conductor, the material
in the conductor, the just there are multiple things
And so we have to rely on what the TESP tells us
Each TSP has their own rating methodology that they
use to protect their equipment. So if we get a rating
from company X or we get a set of ratings from company
X, we have a set of our systems hold four ratings actually
And we get a, those set of ratings from company company
X for their line. Those are the ratings that we use
for our analysis. Now, one of the first things that
we do when we see congestion is we go back to the
TSP and we ask for confirmation on the ratings and
ask if there's any way that those ratings could be
raised
in some circumstances. The, the conductor itself may
not be the limiting element. It may be a wave trap
or something like that. A smaller piece of equipment
that can be replaced that raises the rating of the
entire line. So we have a process that when we see
congestion on the line, then we go back to the TSB
and explore if there are solutions that can raise the
rating of the line. So that's been done with these
lines that has been, that has been done. OK. But we
don't question the methodology that's being used. That's
we've got 25 different T SPS out there waiting lines
And so because this particular juncture is a repeat
offender on the congestion map, right? I mean, it's
been showing up now for several months. OK. How will
the the addition of the new Rio Grande Valley lines
um impact this kind of situation? Is it going to improve
or is it gonna be? Well, it's,
it's on the south side of the congestion. So it's not
gonna have the Rio Valley lines won't necessarily help
us. I don't think the new San Antonio uh line that
was just, just approved by the board. I think you guys
are about to look at that will and there are also some
configuration changes that, that we're exploring with
some of the T SPS that can be put in place during
times of high loading. It's not something you would
want to keep on the line at all, all the time but
there are some configuration changes that you can use
that will also help decrease some of that. So there
is, there are some things that, that will help. The
biggest thing that would help generation north of San
Antonio.
I know that's the, that's the remedy that would, that
would make this go away pretty quickly is if we had
more generation uh north of San Antonio, north of the
north of the congestion. So let, let's talk about a
generation south of San Antonio though. Um So we couldn't
get it north and they were sort of battling um phenomena
being experienced on the system. At the same time,
a surplus of power backing up in the South uh and a
deficit of power being experienced in the north. A
declining uh amount of uh generation. Um You say that
uh ERCOT was forced to direct manual curtailment of
1590 megawatts of generation from the South region
due to this contingency um in terms of management best
practices, uh an overarching question has been raised
uh in industry circles of did this exacerbate the frequency
problem uh that we were experiencing at that time by
reducing so much so quickly uh over such a short amount
of time. What was your experience? Yes, it did exacerbate
the problem, but it was a balancing act. Yeah, protecting
the system equipment versus maintaining frequency and
balancing generation and Load. So the operations group
was, was forced to balance both things in a very short
matter of time. And uh the outcome was good in this
case, the uh if you think of the uh San Antonio, the
I 35 quarter north of San Antonio as a, as a loads
sink an area that requires a lot of generation flowing
into it. A lot of power flowing into it during the
day, you've got 12, 13,000 megawatts of solar, well
maybe not that much coming out of the west. You've
got a good portion of solar flowing into that as that
solar ramps down
that power still and especially on September 6th where
that power struck around late into the afternoon and
the evening because it was kind of humid and hot and
the sun is going down a little bit earlier than it
did back in June and July. So that ramp occurs a little
earlier. So the loads a little bit higher,
that Load has to be served and it starts pulling power
from other places. They can't get it from the west
anymore because the solar has gone down and the wind
wasn't responding on that day.
And so, uh the west wind wasn't responding, I should
say. And so it starts pulling it from the south and
that's the unusual set of circumstances. It's late
in the summer. It's exceptionally hot. The ratio of
west wind to south wind was very low. We're at the
bottom of the solar realm. We had some outages in the
north. So all those things together created this circumstance
that the operators had to respond to.
(item:28:Commissioner Glotfelty asks for details about grid event) Can I ask you one other question real quick? And that
is, so we talk about adding more generation in the
North. If there was a larger demand response program
in the North, would that have solved the same issue
or could have been a part of the solution north of
San Antonio or north of the?
(item:28:Commissioner Cobos asks about frequency issue) So what do you just to try to understand on the frequency
issue? You're you're saying your in your forensic analysis
you're gonna go back and try to really try to examine
the PR C level and the drop in frequency and what what
drove the sudden drop in frequency in the in the next
report? Um And then secondly, I think it might be helpful
based on this discussion to talk about, you know, to
address, you know, what the transmission constraint
issue, the north, the south and, and the um I think
maybe not just the dynamic line rating issue, but maybe
it's a system operating limit methodology issue just
to kind of think about. Well as the state continues
to grow, especially in the South Zone with more population
more transmission being built is the methodology that
ERCOT is using today, the appropriate methodology in
the future.
So I was uh I was thinking about
what it would have taken to have that San Antonio line
in place now.
So it would take us all the way back to the 2017
regional transmission plans.
Ok. So we have to go back that far if in the
20 think about the circumstances in 2017, our peak
Load in 2017 was less than 70,000. We're at 85,000
we had um roughly half the wind in 2017 that we have
now nameplate. So you got another 15 to 17,000 megawatts
of wind that has to be located somewhere to get from
2017 to today. And where that gets located is really
important. The amount of solar on the system in 2017
is about 1000 megawatts. So there's another 12 or 13,000
megawatts of solar that has to be located somewhere
in a planning study looking at 2023. So if we had done
a study in 2023 and we had accurately placed 15,000
megawatts of wind and 15,000 or 14,000 megawatts of
solar. Our Load forecast
for 2023 was 80,000.
So we missed the Load forecast by 5000. So there's
a Load forecasting issue. We would have had to have
a scenario where we bumped the Load forecast up even
more. But more importantly, we would have had to anticipate
that those central Texas counties are where most of
that loads gonna be or a lot of it.
And so if you could, if you had made all those assumptions
located, all that new generation in the right places
bump the Load forecast up and accurately place the
Load where it needed to go.
We might have recognized this line in 2017 in the RT
P as it is, it wasn't recognized. This need wasn't
recognized until the 2021 RT P. Another factor is that
in 2017, we didn't have a congestion cost test, which
we have. now, we didn't have a resiliency test, which
we have now we didn't have any consideration at all
for some kind of multi value approach for, for building
new transmission. So there were a lot of factors back
in 2017 and 2018 that it was, it was really a different
paradigm than for building building transmission. Several
I it was different for everything. It was very different
then. And so there were a lot of things that would
have had to fall in place back in that time frame in
order to bring an endorsement to the PUC. Have you
approve it and then be able to actually build this
line and have it in place for this summer.
(item:28:Commissioner Glotfelty asks about FACs devices or other solutions) Are there things in your analysis going forward that
you could look at like fax devices or other things
that could reroute electrons upon onto different lines
that might help
solve this? If this becomes an issue between now and
the time the Santonio line gets built, I would just
ask if, if you all could put some thought around that
Um That might be something that we would consider ordering
if we could in order to create a more stable system
if those instances, what can we bolt on? Well, we're
working with the P SPS in the area to, to find some
mitigating solutions to get us by until and, and that
may very well be one of the things we come up with
OK. Thank you. (item:28:Commissioner Cobos asks what can be done before new line is built) So, so mitigating solutions, I think
what, what you guys are trying to say is what can we
do now until the CPS energy transition project is built
So that if we hit another situation where we have,
you know, the north to north to south zone or some
kind of, you know, operational issue that you guys
are not put in a position to back down more power than
you need to and, and that you're looking at not just
you know, more transmission but um operational tactics
like system operating limits, dynamic line reads, things
to uh make sure that we're not, you know, overly backing
down the power in the south, recognizing that you need
to have transmission reliability and not burn out the
lines? Right. But are there ways to sort of look at
those operational tactics now with this new um this
new environment that we're in with a higher growth
and you know, more solar and wind, it's proactive analysis
you know, I mean, we we'll explore whatever is out
there?
(item:28:Chairwoman Jackson asks if ERCOT is getting the info it needs) So is it fair to say that um you know, the incident
is gonna kind of point you to some areas where you
want to kind of question if ERCOT is getting the information
that it truly needs the accurate information, it truly
needs. Well, I think that the grid transformation that
we're going through right now is starting to uncover
some of the deficits and some of the things we receive
And so as we go through situations like on September
6th, we're going to find places where we're gonna need
a little extra something here or some more reporting
on this area or something like that. And so as we go
uncover those things, we'll ask for them and it may
come through as protocol changes, it may come through
as a change in the definition of the PR C. But we
will, we will continue to correct and adjust and tune
processes and systems as, as the grid continues to
change, and we'll try to anticipate these things as
well, not just react to them but try to anticipate
them where we can. So you not only look at just this
particular incident, but also the broader system to
see if some of these things would be applicable or
if you needed to go back and actually dig deeper in
some of the other areas in terms of information that
you need. And in this forensic analysis, will you be
further exploring how the battery is performed.
Thank you. (item:28:Commissioner Glotfelty asks hypothetical about wind, DC line) In your view. If we the, the
the RPG um is, has been looking at a DC line from
West Texas to kind of in the San Antonio area. Um If
we had had that, would that have helped or exacerbated
if the wind was robust? I, I don't know what the wind
condition was out there. We had plenty of wind than
in the west. If the ratio of west wind to south wind
had been higher, our existing system would have, would
have made everything work. We wouldn't need the DC
line. Got it. Ok.
Yeah, like I said, it was a combination of several
things and, you know, we've had several tight evenings
this summer and in most of those evenings we've had
things move in the right way in a positive way, had
rain in Houston one night and a lot more wind than
expected on one night, you know, things like that on
this particular night. It didn't move that way and
the, uh, the variables moved against us instead of
for us.
So, you know, you wanna know where I was when I got
the call on the EE A two,
I was at dinner with the first Commissioner, Mark Christie
and NERC CEO Jim Rob. He was sitting right next to me
and I got to tell him we're in the EA2
Uh, so I know you've kind of reported on EE A too
I don't know if we had any more discussion on that
but (item:28:Connie Corona notes enforcement relevance of PRC, telemetry) commissioners, if, if I may, uh ju just to complete
um, some thoughts that, that you might have over the
next couple of weeks while you think about this situation
and our next steps going forward. Um, this, this PR
C issue, um, is among the reasons that our enforcement
division has been focusing quite a bit on telemetry
um, over the last several months. And if, if you look
back at your, at your case docket, you will see that
there are a number of cases where they have pursued
telemetry issues and, and that is just one of the pieces
to the puzzle here as we review Pr C and whether it
was in fact providing the ACOTT operators the information
they needed
point well taken. Um, (item:28:Chairwoman, other commissioners ask about conservation appeals) I know we discussed the, uh ee
A two, but we've also had, you know, a number of recent
conservation appeals and we, we did get pretty, pretty
good response on those and I wondered if you could
just take a few minutes and just give us a recap of
that as well. Yeah, so we are very pleased with the
response there. Um If you look at the Load shapes enough
and you watch them enough, you'll begin to see days
when you can see the conservation, um, kick in instead
of having um, a peak and you'll have a plateau or makes
it look loads shape and So on days when we've asked
for that Texas has, has responded well, and I think
it has made a difference.
I just wanted to make sure that we recognize that and
we recognized everybody's efforts because it, you know
unusually hard times with the, with the summer temperatures
and the challenges that we've had that Texas have really
stepped up on their, on, on conservation and it has
really helped out on average. How much do you see in
Well, it's a so on some of these days when you've had
a voltage reduction and RCP and conservation appeal
we don't have the resolution to divvy those out and
see which ones are, which, so we see an aggregate response
Ok.
Is, is this gonna be the future? What do, what do you
think? Is this, uh, something you see these solar ramp
down type evenings? Yeah, seasonally adjusted, you
know, a little bit different as we, what about winter
I mean, when we start to see that, that winter, the
magnitude of the ramp won't be as, um, it won't be
as impactful. I think the tightest hours in the winter
will be before the sun comes up. Right. So people will
wake up, turn their heaters on, businesses will start
up, right. We'll see a peak and then we'll see solar
ramp up. So solar will be ramping up to get us out
of tight conditions in the winter as opposed to ramping
down in the summer. Right. And there is a, also an
evening peak in the winter as well. It's not just in
the morning, but typically the morning is the, is the
tighter higher peak.
I think communication to the public on, on this new
sort of environment we're in, on, on where we're experiencing
tight conditions when it's dark. Whether it's in the
morning in the winter or at night is, is important
because I think there's a lot of confusion out there
still as to why we're conservation call at night, people
are at dinner and they're getting conservation alerts
Um And then now in the winter, you know, we'll potentially
be experiencing these types of circumstances. So the
more information communication we get out there so
that the public understands why is asking for conservation
when it's dark outside is a, a really, I think a good
um, a good, you know, thing to do because I know that
when we were in E A two, there was a lot of
questions I got too as to why I had to, you know
go outside and get on the phone at night about emergency
conditions. And it's, it's just, you know, I think
the general public I think would benefit greatly from
understanding that why those, what factors are driving
um, the conservation calls at these different times
of the day, they're not used to. Understood. Yeah.
Woody, thanks for being here uh important for the public
to gain an understanding. Of the events that led up
to the E A and really appreciate you being here today
(item:29:Project No. 54445 - CY 2023 Review of Rules Adopted) Ok. Next up is item number 29 project number 54445
2023. Review of rules adopted by the independent organization
regarding OBDRRO 47 revision to errs S procurement
methodology regarding unused funds from previous terms
Sheila, do we have anyone from the public signed up
to speak on item number 29? No, ma'am. No one has signed
up to speak on this. Staff did file a memo and a
proposed order for your consideration. Ok, so we do
have staff here. If anyone has any questions,
madam chair, I would move that we adopt the proposed
second. OK. We have a motion and a second to um approve
the the proposed order. Uh All in favor say I I motion
passes
(item:30:Project No. 54584 - Reliability Standard for the ERCOT - Woody Rickerson) next up is item number 30. Project number 54584, the
reliability standard for the Acott market for the reliability
standard. Acott is modeling 48 scenarios. Today we'll
discuss the modeling results of the 1st 24 Sheila.
Do we have anyone from the public signed up to speak
on item number 30? No, ma'am. Ok. Woody. Would you
want to come on up and tell us about the results,
Woody Richerson with ERCOT.
So the last time we talked to you, we had given you
uh some preliminary results. So the memo we filed has
the 1st 24 of the 48 results that we'll have by the
end of the month. So the table has 24 of those, we'll
get 24 more later. There are eight bullet points there
that represent changes that were made in the model
tuning and improvements that were made in the model
After those preliminary results were run, these are
things that were changed to get the, the, the that
are included in these 24. Some of the significant ones
I won't read them all. But some of the significant
ones are that uh the second bullet, we implemented
a thermal outage reduction success factor of 85% to
reflect the impacts of the commission's weatherization
standards.
Um The last couple of bullets there, uh we updated
the resource mix based on the May 2023 CD R. And in
consultation with the imm, we changed the cone value
to 100 and 19 dollars per Megawatt year, 100 and 19,000
per kilowatt year.
So those are the uh those are the changes that went
in to run these results. And then um just some of the
scenario analysis steps here. So like, like we talked
about before, we have a, a three part frequency duration
and magnitude reliability standard. And it includes
a exceedance probability and the exceed the easiest
way to understand the exceedance probability is that
it represents the outlying distributions that your
reliability standard will not cover. So if you make
it 100% then it'll cover everything. 98% you'll have
2% of the outliers not covered. And so you'll see those
numbers in there as well. We started with the December
22 CD R. We updated it. 3000 megawatts of coal were
removed in all the and there's also 900 megawatts of
gas steam retirements removed. Um So the way this,
these scenarios are set up was the model then had CTS
added back in to achieve the frequency of one in 10
1 in 15, 1 in 20. So the base is a one
in five frequency blocks of CTS were added back in
to get to one in 10, 1 in 15 and one in
20.
Um All the mixes, all the, all the scenarios include
100 megawatts of rooftop solar and 3000 megawatts of
batteries.
The uh no, no win was added to speak of. Um And
you'll see two different kinds of scenarios here. You'll
see one where just blocks of CTS were added and then
you'll see another set of scenarios that have identical
parameters. But instead of adding blocks of CTS, we
add a generation in the proportion that they are represented
in the CD R
and in the table, it shows you the amount of dispatchable
generation. So if you think about that, um that CD
R mix, there is a portion of that, that is dispatchable
That's all that reported in the table. And so when
you see that CD R mix, there's a bunch of bunch of
solar and batteries that are being added along with
that. So if you want to look at the uh those results
I'll go through those real quick. Um If you wanna look
at maybe row number one and row number nine.
So the yellow, our road number one is if you add CTS
and row number nine is exactly the same except you've
added a CD R mix. And so in both of these, the
frequency, how often you should expect an event is
one in five years. In both of them, the duration is
15 hours. So if an event occurs, it could be up to
15 hours in length and the magnitude, the amount of
megawatts that would get
would be involved in a, in a uh a loaded rotating would
be 14,000. So those are your, your three standards
frequency duration and magnitude. Um If you look at
the first column in the scenario, outcomes, it gives
the expected unserved energy. And you'll see that in
row, number one, there's 7633 Megawatt hours and a
similar number in row number 9, 7731 Megawatt hours
So that's your expected unserved energy. In both of
these cases, nothing was added because we're at a one
in five. So we didn't have to add CTS. And if you
look over at the almost not the last column, but the
next to last column, you'll see the exceedance probability
for duration and the exceedance probability for magnitude
which are two separate things. So going forward, when
you get the rest of these results,
I would suggest
that decisions are made about exceedance probability
First,
what kind of exceedance probability is tolerable for
our reliability, standard color or unacceptable? Either
one which I mean is it, should it cover 98% or 95%
or 90%. So that will having that number will help us
narrow stuff down. That'll be one. And then of course
you've got your three frequency duration of magnitude
but, but those those together will, will, will be the
things and there may be things that you say, you know
you right now you have a magnitude of of 14, 10 and
five, maybe you want 16 or 18.
So those kinds of inputs are what we are looking for
for the next round of iterations.
(item:30:Commissioner McAdams asks for comparison example such as 2011 event) So I know what I'd like to know just as, as a
a an example of something to compare against. Um I'd
like 2011, the event of 2011 broken down into a duration
magnitude uh event like what was it? Um I think I've
got the duration but I want ERCOT to do it, you know
so you apply your methodology, but I wanna know what
that was when I compare this, this table to it.
We can follow. I know what that felt like and I know
what 21 felt like. That is definitely not good. So
once we kind of have that comparison, we'll, we'll
know what that looks like. OK. And we're also working
on a prompt here as requested by the IMM. And that
will tell us where we are. I think it's for next summer
What the frequency magnitude rate where we stand as
of next summer? Yeah,
so one of the question. Oh yeah, sorry. Commission
If you want to keep going, you can. Well. Uh So one
of the other questions I had was the sensitivity of
weatherization effectiveness. Um The the weatherization
effectiveness. That's our, that's a, that's an input
that is an assumption 85%. Um Now we have standards
that we will hold generators to but um
I, I believe this is gonna need to be looked at moving
forward on a uh iterative or periodic basis. Um Once
we adopt a standard, I would like some of those base
uh components of the framework and evaluation to survive
for a while as uh ERCOT and the commission iterates
Um
Could we, do you think it's appropriate to have? And
I keep thinking about the natural gas boom of 2011
through 2020. Uh the collapse in natural gas prices
the price signals to generators in an energy only market
their interest in investing in some of those units
And thus the, the the success rate of those units and
actually staying online during winter storm Erie, because
II I think we highlighted a problem that there was
not enough revenue in the system to drive generators
to reinvest in their facilities and thus harden them
and to survive a weather event. Um I, I think that
was certainly implied. So I'd like to see a range of
of assumptions on that weatherization scale. Like how
does this perform if 85% is too optimistic or if it's
not optimistic enough, um just to see how that impacts
this. Yeah. So for this analysis of these 1st 48 we'll
keep it at 85. But for future iterations, we can move
that number around and give you some sensitivities
to see if that, if it was 100% or whatever going forward
as we, as I anticipate, we will run this every year
That number will get more and more informed based on
performance that happens during the actual winters
We don't have a whole lot to go on yet, but we'll
have some more winter storms and we'll get to see just
how good the performance is and we can tune this to
match actual performance built in performance based
accreditation. So when you say yearly basis, you're
you're gonna run basically that, that like you said
duration magnitude to just kind of get a picture based
on the CD R mix or C just kind of do it
on an annual basis, will that take into account seasonality
Like for instance, CD R mix is, you know, the resources
and the planned resources that the planned resources
in the CD R mix or CR for rather all have different
attributes during summer, winter, right. So would that
capture seasonality? Like, you know, solar is pretty
high in the summer but not as high in the winter wind
you know. Yeah, so it's using a uh annual. When you
do the probability analysis, you're looking at a year
of solar data, a draw of solar data and a draw of
of wind data. So you have,
I don't remember how many years or 40 years of solar
data that you can look at and pull from. So every time
you do a run, you're pulling one of those. And so it's
a full year and so it captures the seasonality great
and it'll capture the battery as well. Batteries will
be different because we'll have to, we'll have to put
those in
that. That, that was my question was um in all these
scenarios you talk, you, you, I think appropriately
use uh or you measure eu e you know, kind of one
of these new standards that we may um uh utilize in
in painting this picture. Um And then you have new
megawatts of dispatchable resources. Is there a way
um to, you know, if, if we look at our interconnection
queue, um If you look at line two for one in 10
Um, you're adding 2900 and 68 megawatts from AC T
to translate that into Megawatt hours and to determine
uh, where we stand with the, I'm thinking for this
coming summer for this winter with the new onslaught
of batteries that are coming on the system. Can they
help that situation? Can they reduce that number of
CTS needed? Um, and I know there's a bunch of assumptions
in there. Are they two hour batteries, are they four
hour batteries? Are they one hour batteries don't scare
Woody Jimmy. But uh
I'm just wondering, does that help us get a better
picture of where we might be?
Do you think that's a different analysis giving you
an hour? Do you think that,
are you asking for the capacity factor of the new generation
Uh No. Uh what I'm, I guess what I'm really just asking
is, um, do you all believe the delta between the CDR
and the scenarios that you've created uh are realistic
in terms of what is actually happening on the system
with batteries and the number of megawatts that you
would add in terms of AC T, if you translate that two
into a Megawatt hour, would batteries actually
substitute? Right. So the model will incorporate, both
incorporates the behavior of both? Ok. Ok. Um We're
still learning what battery is doing. Yeah. So that
behavior may change in the model a little bit as we
learn more, but we do incorporate that in the model
now. So there, the behavior is there. Um
I don't want to go out on a limb here because I'm
not running the model. But conceivably, maybe you could
add just batteries and not CTS and see what would happen
I'm not for sure if that's, if there's that capability
or not, but we can explore that. Ok. That'd be great
Um
So 11 of the look high arching thought on on a path
forward here, I I think this is good. The draft is
is a, is a great example of how it's iterating forward
and narrowing the cone for us. Um I think I URCO no
matter what should be allowed to continue on this approach
that they're on and we'll see this further start to
to narrow. Um
II I think from this point forward, from what I'm gonna
be looking for this, we are now entering the peer review
phase of this process. So the collective intelligence
of the market needs to come to bear on this. Uh We
we're in uncharted waters as is SPP and the other is
OS. So I think um we need everybody to evaluate what
are the metrics, what are the assumptions, what are
the methodology being employed in this model and start
to provide feedback so that then we can really start
to narrow the cone um and provide us a better uh uh
field of options rather than a broad universe, um,
that we can, we can start to debate. Ok. What are the
pluses and minuses? What are the features and, and
the downside risks of each? And, um, and that needs
to happen over the next month.
So, after we deliver the second set of these assumptions
and we don't have anything else on our plate to run
yet until we get direction back.
So, Commissioner McAdams, are you contemplating after
er, is done with all of the 48 scenarios? Getting feedback
on them? Yes, at the puc or? That's right. And, and
I think, I think they can, this is an important first
look because they're starting to see what you're using
what your inputs are and what are the, how, how this
and we want them to come at this from their own, uh
unique company perspectives. You know, there's winners
and losers in any way we cut this. I wanna hear that
feedback. I wanna smoke this out. We're already hearing
that we shouldn't be comparing this against 100% CTS
but it should be combined cycles. Um So there's gonna
be every time type of comparative, you know, metric
thrown out there. Uh We need to see that, uh, and then
ultimately, you know, di different benchmarks like
2011 or what is the appropriate comparative scenario
As a commissioner, we're gonna need to know that from
a health and safety perspective, from a uh economic
risk and economic cost perspective. Um But, but the
market will help inform us on that. So we can, we can
debate how long of a turnaround we expect that. But
I believe between now and mid October is gonna be an
important period. Uh The ERCOT board will meet um in
mid October. Uh and, and then we start to issue instruction
on how this will be significantly narrowed.
Does that make sense? I think it does, I mean, right
now we're in the process of trying to give ERCOT direction
on where we want to head with all these 48 scenarios
And what you're looking for is additional feedback
from the market from the stakeholders to help us. Sort
of, is there something we're missing here? We need
to know, are we missing something? Is ICO missing something
Um And I can tell you I sent this over to SPP
I haven't heard nothing back. So I think you're way
ahead of them right now. So I'm, I'm trying to get
that to where and, and I would say on the uh resource
adequacy, uh work that I'm doing with and others. Um
I mean, they are looking to ERCOT because uh lots of
discussion going on out here and they're looking at
us and going, they're actually doing this. So it's
a, it's a uh a credit to offer uh leading the pack
but we need, we need the market, it's a big broad market
They beat you up all the time. They need to provide
some feedback um on, on, on how this thing moves forward
Well, if it's useful for us to hold a workshop or,
I don't know how that works, what, what, what process
you want, but we can work it either way. Yeah. Uh Well
I, I've got recommendations on how to utilize the time
on workshops in between, you know, and, and we've got
to face first things first too. So I don't wanna populate
our calendar with workshops on that. Uh Just yet because
um it may be better served. We, we've got a winner
approaching as well. And so I, I know there'll be a
lot of discussion on how to utilize the time in October
October is an important month. Well, I think to your
point, what your challenge is, as I read it is, you
know, from a technical standpoint to have the market
participants take a look at it. It doesn't necessarily
need to be the end or along the way in terms of
a formal stakeholder process, but they're evaluating
this as we move forward and to kind of reach out with
their technical observations as we move forward. I'm
gonna use an old legislative phrase, you better discuss
the menu or you're gonna be on the menu and so they
better be engaged on the front end on this. Um We're
all in this together and uh if, if we wanna make this
market work, we're gonna need feedback from the market
Well, the next filing you see will be the full 48.
It'll be this chart filled out completely. So, so woody
we talked a lot about, um, the increments and the various
scenarios. Um, can you just take a minute and just
talk about the base and how the base was the base assumption
was developed? And, um, with, I guess the thought being
at some point in time, we could do some flex cases
off the base if we're thinking that maybe there might
potentially be more wind and solar batteries. Yeah
So the to what's currently in the base, right. So the
adequacy team um provided a, I think in the filing
that development steps and that pretty much describes
how the base. So the base was configured to be to start
at a frequency of one in five years. So the generation
was taken out of the case to get to that point, which
is not a conservative number. I mean, that's, that's
a lot of stuff that a lot of stuff we don't know
exactly some of that was coal capacity that many people
anticipate may, may be effective, but that wasn't the
driving factor there. It was. And then there's 900
megawatts of gas that was taken out as well. That,
that is on the books to retirement. So that, that and
then it was updated with um the May 2023 CD R and
we also use the May 2023 CD R to get the proportions
of what people are expecting to add to the system.
So the, the all CT versus the CD R mix, that CD
R mix is based on the May 2023 ratios of what people
are expecting to put on the system. So I I don't have
those numbers in front of me, but it's a lot of solar
a lot of batteries, a little bit of, a little bit of
thermal. So one option we'll have moving forward is
to kind of take a look at um potentially a scenario
where we go in and say there's actually more than what
we anticipated in terms of resource mix associated
with wind and solar and batteries. And then I guess
directionally, if we would do that and move more towards
wind solar and batteries, then theoretically this exceeding
probability um would go up, we can do that. We can
run that scenario. You can also consider what the low
interest loan program, what effect that has. Well,
that's why I was so thrilled to see some of these numbers
I mean, like, well, hey, we can do this. Uh but, but
let, let me ask you a question on that because, well
you, you just, we can do this. So if you look at
line 10, um it says we're 22 26 megawatts short. But
is that a real reflected number or is it really 22
26 in 26 minus or additive 900 of gas CTS that you
took out and 3000 of coal capacity that you took out
Yeah. So the, so the hole that we're trying to fill
is not 22 26 it is 22 26 plus 3000 plus 900
Well, the PCM isn't around yet so you don't have to
worry about that. No, no, no, I'm just, uh, I, I'm
trying to make sure that, uh, we, we're not looking
at, we're just 2200 megawatts short in 2026. We're
really more than that. If in fact EPA regulations go
into effect and markets continue to devalue, uh, the
energy associated with it, it goes back to the old
argument of is this stuff really gonna retire? You
know, this is an assumption that drives that number
and we can run scenarios around those assumptions.
But the 3000 megawatts that you took out wasn't based
on EPA or anything, it was just to bring the standard
down to one in five. So there's no basis. So the, the
resource adequacy team wanted to have scenarios that
were reflected as in frequency, first one in 51 in
10, 1 15 and one in 20. And so they dialed in
those numbers to make that work and then they let the
duration of magnitude come out like they did. So the
the, the additions to the to the base model were made
to get that frequency into those segments. But, but
the good thing is is that uh that resource mix was
entered into the serve models encapsulating all those
events over 1000 years. And um we're, we're within
striking distance theoretically on a planning basis
And that's the difference between planning and operations
of, of achieving a, a more conservative or uh safer
uh standard for the system.
There's light at the end of the, yeah. And keep in
mind too that it's not the capital cost of additional
ct generation. That's the, the carrying cost. It's
not the all in cost. It's the payment you'd have to
make to get that generation. It's an annual cost, not
a
not capacity cost. I I worry that people are uh the
the market's a little bit asleep at the wheel and on
what you're demonstrating here, that's why I use that
legislative analogy and everybody kind of woke up in
the room. Um Th this is gonna be a, a big policy
driver and, and we need, this is the time to engage
I think.
Thanks for,
thanks for being here today and we look forward to
seeing the remainder of the 38 scenarios at our next
open meeting on September the 28th. Um It seems like
we're at a good stopping point for a quick break to
allow time for the court reporters to switch for recess
and we'll be back in just a few minutes.
Mhm.
The commission will now resume its public meeting at
11:41 a.m. (item:31:Emergency Pricing Program - Proposal for Publication) Next up is item number 31. Project number
54585. This is the commission's rule making regarding
the emergency pricing program. Today, we will discuss
the proposal for publication. Sheila.
Do we have anyone from the public signed up to speak
on item number 31
speaking for Sheila. It doesn't, I don't see any memes
on this. So, no,
I'm so sorry. We started without you.
So do we have anybody from the public signed up to
speak on item number 31 31. No, ma'am. Ok, thank you
Um David spelt with the PUC staff is here, David, would
you please um provide a brief overview of the proposal
for publication? We have Warner Roth from our uh market
analysis division and he is the leap thinker on this
one.
Um Good morning chair Jackson commissioners, I'm Warner
Roth on commission staff. Uh So this rule making, as
you said is to implement the emergency pricing program
as required in pr 39. About 1 60. This new program
would serve as a circuit breaker to limit financial
exposure for consumers after ERCOT has had at high
energy prices for an extended period of time. The rule
language was added to 25 509 of the commission's subset
of rules and contains the following provisions. First
the rule establishes triggers for both the activation
and termination of the emergency pricing program. The
program would be activated as required by statute when
the system wide energy price has been at the high system
wide after cap for 12 hours within a rolling 24 hour
period. For termination of the program staff has proposed
having the program remain in effect until the later
of either 72 hours after the activation of the emergency
pricing program or 24 hours after he exits emergency
operations. Next. While the emergency pricing program
is active, the system wide cap will be set at the emergency
offer cap. Staff has proposed that this value would
be equal to the value of the current low system wide
offer cap. Next. Um The this rule would create a reimbursement
process as your part in statute for resource costs
that exceed the emergency offer cap. While the emergency
pricing pricing program is in effect, staff recommends
aligning this recovery mechanism with the one previously
approved by the commission for application for when
the system wide offer cap is set at the low system
wide upper cap value allowing for the recovery of actual
marginal costs in excess of the offer cap.
This rule would also create a couple of additional
requirements for ICO ERCOT would be required to issue
a market notice at both the activation and termination
of the emergency pricing program. And additionally
ERCOT would be required to file a report with the commission
following an event that triggered the emer emergency
pricing program. This report would include um in from
staff's initial proposal, a summary of the event that
triggered the program, an analysis of the market performance
during the event information on the recovery of costs
and excess of the emergency offer cap and any recommendations
for further refinements to the emergency pricing program
And then lastly, this um rolling would also create
the requirement for the commission to review the various
offer cap programs every five years as required by
statute starting in 2026. Um The identified offer cap
programs that would be included in this review would
be the high system wide offer cap, low system wide
offer cap and this newly created emergency offer cap
And with that, I'm happy to take any questions. And
the only thing I'll add is this is one of the key
provisions from SB three from last session. And we
view it as a sort of a central customer price protection
sort of piece of legislation. And the, the, the reason
it's coming before you now is we are gonna try and
get this thing done uh in anticipation in advance of
the upcoming winter season. Very good. Ok. We have
any thoughts uh (item:31:Commissioner McAdams on section about reimbursement) madam chair if I may. Um I'm just gonna
read uh the section that relates to reimbursement for
costs that exceed the EC um as per the proposed rule
um for publication. While the Epp is active ERCOT must
reimburse resource entities for any actual marginal
cost that exceed the greater of the EC or the real
time energy price for the resource ERCOT must utilize
existing settlement process to the extent practical
to verify the resource entity cost of reimbursement
Um
Unfortunately, the price of power is often influenced
by commodity prices for which we have no control. Um
And I I think winter storm y was the most vivid example
of how that could have unintended consequences and
undesirable consequences for uh ICO consumers. In my
view, we cannot allow seemingly arbitrary price changes
to be borne by ratepayers without some limiting factor
And I believe that's the intent of the rule and it
was the intent of the law. Um And therefore, I would
urge the commission to consider as we go into the,
the proposal for publication of which I am not suggesting
any changes at this time. But uh did the commission
considered language setting an upper limit to the reimbursable
costs? And I'm not prejudging what that would look
like. Uh I'm certainly interested in what the market
uh stakeholders will submit in terms of public comment
But uh it for discussion purposes, it could be as simple
as some type of reference to the age cap because again
the intent of this program is to limit the exposure
of cost to consumers and by not referencing high cap
or some type of upper limit as a bound boundary, um
it could be construed as gas can be whatever it wants
Uh generators have to pay it and thus we have to pay
it. And the Public Utility Commission of Texas has
always had one bit of leverage in terms of this market
And that is no cost can exceed the high cap in terms
of bid prices into the system. And so we need some
type of limiting factor,
very good. Um The commissions I've had talked about
um including something like that. But um pre previously
when we implemented a similar um mechanism for the
when the low system cap is in effect, we did not include
a um cap on that provision that is in 25 509, which
is the rule opened up by this rule making. So if we
were going to um apply to such a change on the EC
and put a cap on that, I would also recommend including
something on the LC provision as well. However, you
choose to, to move forward or just know that one vote
we'll have a say at the end of this. And, and so
so to clarify, I think we're not going to be changing
anything, we will move forward as published. But to
those that are listening, we're particularly interested
in comments on whether or not uh when the uh emergency
pricing program is in effect, if there should be a
cap on how high the expenses that can be recovered
are. And that's at the request of Commissioner McAdams
and Warner is also noting that a similar lack of cap
situation exists when the L cap is in effect. And so
um comments on whether or not those two programs should
be viewed separately or differently for these purposes
uh would also be welcome.
You have any more comments? Ok. Um (item:31:Motion to approve proposal) I would move to
approve the proposal for publication. Uh Do I have
a second? We have a motion in a second all in favor
Say I I motion passes
(item:32:Circuit Segmentation Study - Discussion, possible action, Proposed Order) next up is item number 32. Project number 55182. Regarding
the circuit segmentation study, uh Sheila, do we have
anyone from the public signed up to speak on item number
32? No, ma'am. Ok, David. Could you please provide
a brief overview of the draft order? Yes, ma'am. Uh
This is another important piece of legislation. This
came out of our sunset bill. It was section 13 that
requires us to direct transmission and distribution
utilities to perform a circuit segmentation study.
I think this is an area of high interest um because
you know, the more segmented our distribution circuits
are the more flexibility that these entities have to
rotate Load during loaded situations. This was a, this
was a bit of a tricky wicket because it's not a rule
making. And so Connie had the insight that we should
publish a draft order a few weeks ago, which we did
we got a lot of good feedback. From some of the participants
and we've been working with ICO. So compared to the
draft, we, we made a few adjustments, but some of the
some of the things that I would highlight is commission
staff is recommending approach uh compared to what
some commenters might have uh recommended where we
we view that the inquiry into circuit segmentation
is important but also contain a lot of potentially
sensitive information. And so in line with the apparent
legislative intent that the the core underlying data
gets turned in, uh a summary report is going to be
filed and then commission staff has the ability to
request access to additional information if they need
to advise the commission on any legislative recommendations
you guys have. Um So that is the approach we're recommending
so that we're sort of balancing public transparency
concerns and security concerns. And we put in sort
of an escape patch where if the publicly available
information isn't sufficient staff will recommend to
you guys that additional information be made public
And so we really, we want to thread the needle, but
outside of the rule making process, we try to limit
our recommendations to interpreting the words on the
page and the statute rather than um constructing and
designing a lot of new requirements. And so uh another
another key change that we made is there was a recognition
by some of the commenters that on the transmission
level, ERCOT has unique insight into, you know, requirements
and also reliability of the system. And so we've provided
a, the ability for us to share and get advice from
ERCOT when we're doing our analysis. But also when
the individual utilities are doing their reports, they
can submit the transmission component to ERCOT for
sort of an advisory comments from ERCOT on what whatever
they may seem. So these can be topics or liability
topics. And the reason I wanted to mention this specifically
is, you know, we had a lot on this open meeting, so
we had to pivot and ERCOT requested at least 60 days
uh that they would get the information 60 days before
the deadline. So they would have time to give adequate
review. We didn't have time to check with all the stakeholders
on whether or not this would limit their ability to
successfully complete their studies in time. And so
we made this a permissive requirement. They may consult
with our, but I would say that our recommendation would
be that you take this, this this option if your timing
allows because uh you know, getting better informed
um you know, the, the better informed that this study
is the, the more helpful it's gonna be uh for us in
the tail end so that we can make coherent recommendations
to the legislature on this topic. Uh Do you have any
questions?
(item:32:Commissioner Glotfelty shares thoughts on circuit segmentation) I have a couple of thoughts, not necessarily questions
And that is Circuit Segmentation is, is this is intended
I think to provide flexibility to the transmission
distribution owner when they are ordered to shed loaded
how can we do that allow critical facilities to remain
online while we're still meeting the obligations of
the loaded orders and ensure that the system remains
reliable. And what I would say is I think there are
other technologies that are on the system already that
should be taken into consideration when these things
happen. So rec closure and ami and all sorts of things
that have been part of the fabric of the system for
for many years that the utilities when they're doing
these studies should take those into consideration
not look at this as just a today forward, but look
at some of the things that they have done in the past
and see how they play in may be modified, maybe help
different resources, micro grids and things at the
distribution level to allow more, more segmentation
more loaded in emergency situations. But allowing those
that might have micro grids or distributed resources
to continue to operate for the benefit of the system
So I just hope that uh that we can um look at
that and when we, when we get to the end of this
process and we get to the evaluation of the actual
plans. Um note that we'll be looking at that. So
(item:32:Commissioner McAdams on potential benefits for resiliency) yeah, just, just from my perspective, madam chair members
um I I think the PFP is, is a great uh good
to go. Um I, I would say that I think it's unfortunate
that the segmentation policy is, is really just applying
to our investor owned utilities. Um I, I think it has
uh positive, it could have positive ramifications for
the reliability and resiliency of these systems. They
they are not mutually exclusive resiliency in this
context, segmentation would help in that effort. And
I, I think uh electric cooperatives and municipal utilities
would benefit from that as well. But I understand the
limitations of the law and um and how it was written
So uh just wanted to throw my two cents in there and
and on, on that point, if I may, uh we really want
to make sure that, you know, not every member of the
legislature is gonna understand um uh every aspect
of the way our market works. And so 11 element that
we included in this is for tt us that have mo us
and co-ops that are under them, we want them, even
though even though they're not part of the segmentation
exercise, we wanted a report on what who those entities
were. So that when we compile our report, we can be
very clear about this is what is, this is, what is
and isn't included in this report. And so that they
don't, so that they have an accurate sense of the,
the depth and breadth of the study. Um And that, you
know, like this percentage of megawatts is done by
mou and co-op. So it's not represented in this study
or whatever. And so we want to provide crystal clear
recommendations with regard to that. I mean, that's
that's great because I have a cousin that's on the
tail end of this, a, a rather spindly distribution
system that's managed by a co-op but ultimately served
by um an A P transmission system. So uh there, there
is some, um there's an integrated framework there uh
that everybody has to lean on. So I think that's a
great way to approach it. Thank you some great discussion
(item:32:Motion for order consistent with staff recommendation) And with that, I would move to issue an order consistent
with staff's recommendation. Do you have a second?
The motion in a second, all in favor. Say I I motion
passes
(item:33:Transmission and Distribution System Resiliency - Proposal) next up is item number 33. Project number 55250, the
commission's rule making for transmission and distribution
system, resiliency plans. Sheila, do we have anyone
from the public signed up to speak on item number 33
Yes, ma'am. One person to speak Don Brown. Ok.
I would like to pass this uh to the commissioner.
Good morning. It's your way to get the microphone.
There you go. If you could please state your name and
your affiliation. Thank you. Um My name is Don Brown
I'm a 35 year resident here in Austin, Texas and I'm
here testifying on behalf of myself. Um the following
what I want to submit to testimony is a letter that
we are sending, I am sending to Governor Abbott in
regards to the resiliency of the grid. So we're working
with a large grassroots organization in Texas to give
the governor and the PUC support on working on resiliency
So we want to have your back on this. We want to
participate in it and we're here to build that relationship
with you. So I wanted to give you this letter, He gets
it on Monday. You get it today.
Dear Governor Abbott. I'm writing you today with a
sense of urgency and deep concern. Considering the
state of our Texas power grid. Recent reports from
the Department of Energy have revealed a staggering
1900% increase in vandalism and sabotage to the Texas
power grid since 2017. In just the first six months
of 2023 there have been 19 reported events in Texas
alone. According to ERCOT reliability report, vandalism
and sabotage account for 35% of the grid events from
2018 to 2022. These numbers are alarming and demand
immediate attention. In addition to these concerns
we must also acknowledge the potential risk posed to
us by individuals from foreign adversaries that are
entering across the southern border. It's estimated
and there are reports, numerous reports that hundreds
if not thousands of military age men from countries
like China have been crossing into Texas. In fact,
in June, this comes from the House Intelligence Committee
140 individuals on the terrorist watch list have been
apprehended crossing the southern border in fiscal
year 2023. Furthermore, there's a severe shortage of
transformers worldwide. I'm sure you all are aware
of that with an order to lead delivery time on the
very large transformers of 4 to 6 years. Now is what
I'm hearing from the people that are advising the Pentagon
that scarcity leaves us our large power stations vulnerable
to coordinated military style attacks as we have witnessed
in Moore County, North Carolina that was in December
and then in Metcalfe, California, regrettably, our
utility companies have consistently blocked all efforts
to legislate and establish a standard security standards
including the most recent Senate Bill 3 30 which we
were supporting all through this session. It's crucial
that we overcome these obstacles and prioritize security
of our power grid. If I may just continue just to finish
the letter, the emergency requires immediate attention
before it escalates into a full blown disaster. Hb
25 55 focuses on resiliency enhancements. It is a step
in the right direction. We strongly support this,
the Public Utility Commission. We believe the Public
Utility Commission has the opportunity to fast track
some of these projects on. So there's 10 things on
that list in 25 55 intelligently go after these, what
are the most critical assets and let's fast track them
So, Governor Abbott, I have faith in your leadership
and commitment to the great state of Texas. I urge
you to seize this moment to protect the Texas power
grid, our citizens and our future prosperity and that's
what we are submitting. So thank you very much for
your time. If there's any questions on the back, if
you see the last page, there's the, the report that
you received, you all produced and received that ERCOT
report that shows the 35% vandalism and and um and
sabotage events that happened in the last five years
But the real trend is that is the graph above it because
that's what's really happening. We should be looking
at trend lines, not, not pie graphs on this. This is
what's actually happening. The number of events is
going up, it's going up at an alarming rate. So thank
you very much for your time. I really appreciate it
and I appreciate so much what you all are doing.
Thank you for being here.
Yeah,
David, could you please provide a brief overview of
the proposal for publication? Yes, ma'am. Before you
is a proposal for publication. Um uh Before you start
chairman, sorry to interrupt. Um Let's bring up. Can
we bring up the pro item number 34 project number 55407
Oh, I'm sorry, am I on the wrong one?
Sorry, go ahead.
The uh
sorry. This is before,
before, before us is uh staffs recommend publication
which implements House Bill 25 55 from this legislative
session. We think this is a really important piece
of legislation and it falls into sort of a cluster
of efforts that we have um to uh enhance the uh you
know, resilience of our system. This includes the circuit
segmentation study order that we just did. This includes
our ongoing efforts on long lead time in mobile generation
facilities. Um And this includes this bill and others
And so, uh one thing that I wanted to highlight this
was this was a particularly challenging draft to pull
together. And we, you know, we've been consulting with
national labs working with stakeholders. We had a workshop
already with a lot of good inputs from stakeholders
But just to help focus comments, I want to say that
the challenge, the challenge with uh doing resiliency
is there's not a uniform definition of resiliency.
And by that, I don't mean I don't mean here, I mean
anywhere in the nation, everyone's working on this
and there's not uniform metrics for evaluating resiliency
and every the topology and system characteristics and
resiliency events that each of our tt us and distribution
utilities face are different. And so the approach that
this takes is,
you know, I'm not an engineer, climatologist or any
of those things. And so if staff, staff tried to define
all of the events, it would probably not be ideal.
And so instead the approach we took is where the, you
know, each utility needs to come up or this is permissive
But if they come up with a resiliency plan, they would
do that by looking at their system comprehensively
and identifying the resiliency events that are most
threatening to their system and would most likely lead
to, you know, loaded events or not legit even sorry
that would lead to disruptions in their ability to
deliver power. And so we asked that the utilities define
the events and identify solutions to those events and
those solutions will have to take the form or fall
in the predefined categories in the legislation. And
so that does include speaking to Mr Brown's testimony
that does include both physical and cyber security
So he mentioned that in the last however many years
there's been 19 events. And so if those were in the
territory of one of our utilities, maybe they would
say these are the sorts of events that our resiliency
plan is designed to address, but it may also be hurricanes
of a certain category or wildfires or whatever, whatever
the the critical events are. So they, they define,
they define the resiliency event, they bring us their
best proposal for how to solve it. They explain why
and provide evidence for why that is better than other
alternatives that are out there. And they recommend
evaluation metrics because the way you would evaluate
the way an elevated substation responds to flooding
is different than the way you would evaluate a wild
wildfire protection measure or cyber security event
And so, you know that that is basically the layout
it is going to be the, we put it on the utilities
to define the problems and bring solutions. And then
the commission's role will be in the course of 180
day proceedings to evaluate to make sure that the evidence
in support of their proposals and solutions is sufficient
with the utilities carrying the burden of proof in
these provisions. And so, um I, I think those are the
points that I want to highlight at this stage. And
I believe that there's a, a memo filed in this, this
one as well.
There is. (item:33:Commissioner McAdams lays out memo) And Commissioner Mick Adams, uh you filed
a memo. Would you please lay out your memo? Thank you
madam chair members. Um In, in my memo, I made some
sue suggested edits. And first of all, I'd like to
thank thank David and his team uh commission staff
for entertaining the, the dia the level of dialogue
that they have and formulating the PFP. Um My edits
were filed and I hope that they will help the commission
to better understand and identify where resiliency
needs exist. Um And how to better address them in many
ways. This endeavor is going to provide a new way for
us to look um oh at our transmission and distribution
system and my hope is that it leads to more dependable
grid for everyone. Overall, my memo suggested modifications
to help provide a defined range of potential outcomes
which may allow us to understand how the overall goal
of resiliency may be achieved as a part of accomplishing
these plans and implementing what they suggest changes
to their systems. And ultimately, it's, it's better
it is better for us on the back end or our successors
at the commission to understand. OK. Here's what they
were thinking at the time when they began this, this
journey of enhancing their system. And this is what
success may otherwise look like. They may not hit it
They may not achieve that exactly. But at least we'll
have a better understanding of what they were thinking
and, and how they were going to approach it and where
they ultimately hoped to end. And with that, I'd entertain
any, any questions.
No, I'm (item:33:Commissioner Glotfelty comments in support of memo) I'm appreciative that you uh that you did this
um this memo, I think the additions are in line with
my thinking. Um I would say that um over the last 25
years in this industry, we've uh we've come to believe
and understand that reliability and now resiliency
is driven by not just one action, but it's layers of
actions, layers of technologies and layers of efforts
by operators and others to make our system more resilient
So this isn't the utility just looking today and saying
well, we can put on X to make the system more resilient
It could be that. But again, like in the last in the
segmentation discussion, it could be the discussion
of how these advanced meters that we have spent hundreds
of millions of dollars on in this state can encourage
additional resiliency. It is how other technologies
that are on the system, the rate payers have already
paid for can be part of this system going forward for
resiliency. I'm just hopeful that when these plans
are filed that on the distribution system specifically
that the technologies that are there that are available
may not be deployed just by the utilities, but by market
participants can be woven into this discussion and
woven into these plans to allow for them to improve
resiliency or be additive to the resiliency of the
of the TDUs. The one other, I think I have two more
things, but one is resiliency. Obviously, this is an
issue that uh we, we don't have our definition. Resiliency
is a in the ERCOT transmission planning process is
a additive kicker that we could utilize to help um
make a non uneconomic project economic. If we think
it will be additive for resiliency, and therefore,
I think that we can't skimp on the transmission resiliency
piece of it. I know there were a lot of comments that's
like a lot of this is at the distribution. But if we're
if we're using that as a metric in planning, then there
is definitely a viable uh reason for, for it to be
here. Um And then uh
I think that's all. I, I think I did have one other
thing but it obviously wasn't that important because
I didn't say it. So with that, I'm, I'm supportive
of the uh, of the proposal for publication and I'm
eager to get these plans in action and get them. Oh
no, I know what I was gonna say here. Um, I'm appreciative
that you're letting the utilities define the problem
because of this issue. We've got, we're a big state
We've got different problems all across the state.
If we say resilience is underground and transmission
lines or distribution lines, guess what, underground
lines at the distribution level is not good when you
have storm surge of hurricanes, saltwater intrusion
isn't good for transmission power systems underground
So letting them define this will allow us to have some
understanding of what they're specifically trying to
TAC rather than a blanket proposal across the entire
state. Florida power like underground. Well, they do
and there are some areas where they do it. Substations
are above ground, Florida. Power and light primary
layer of resilience is utilizing concrete poles at
the distribution level. So they've spent uh hundreds
of millions of dollars over the last 10 years and putting
concrete distribution poles in place in those areas
that are prone to hurricanes so that if a conductor
falls because of the winds of a hurricane or because
of vegetation, the pole doesn't have to be replaced
The conductor can just be restrung and that is a much
quicker process.
(item:33:Chairwoman Jackson comments in support of testimony) I think we've made a number of good points particularly
I think the last point you made is how important it
is. You know, for the folks who are boots on the ground
to actually evaluate the risk and think of it in terms
of, you know, that if you will worst case scenario
and what are those mitigation measures that need to
be put in place in order to address those? Recognizing
that again, it's often not one thing. It's as you,
as you stated, layers of things that we need to consider
and also how they work, uh they work many times, you
know, in in conjunction with one another. So recognizing
that, you know, we have, you know, as staff has put
together this kind of process in place to develop the
plan. And then I think our hope is that, you know,
as we move forward, recognizing that there is this
diversity across Texas, but there also would be an
opportunity for information sharing. And so as the
plans are developed, you know, I would hope that, you
know, people across the state will be cognizant of
what is being developed and kind of ask that question
you know, is, is this is, is this something that could
be appropriate, you know, in, in my particular situation
And and then uh the whole concept of develop, developing
the metrics to determine, you know, how well you know
these mitigation processes are performing and then
this whole vein of, you know, putting this in place
and having a process of continuous improvement. So
um just so so important that we move forward. Uh because
again, there's a growing expectation from the public
from reliability, as well as resiliency and addressing
this, you know, for the overall system. But again,
recognizing the differences as we move forward, so
I really wanna appreciate the help and the work that
the staff has done and also kind of look forward to
the work that the entities will do as they develop
their plans. And so look forward to seeing them. (item:33:Commissioner Cobos comments general agreement) I
don't know that I have a whole lot more to add. I
in general agreement with all the comments made today
I think resiliency obviously is a very important topic
these days in every market across the country and probably
globally is looking at it for, for one reason or another
it's not defined. But I like the idea of putting in
the utility hands of defining what resiliency means
for their specific service territories and the challenges
they may encounter in in those territories. Um I, I
like the sort of general statement you made dude and
and I think Commissioner Glotfelty alluded to is resiliency
is woven into a lot of legislation that has been passed
last session and this session, not not only the legislation
um prompting this this effort, but also, you know,
you have on site mobile DG, we have Senate Bill 12
81 where we added a component of resiliency. I think
it, it would be really helpful to sort of tie everything
together. Um and, and look at it more broadly and holistically
so that we're um not overlapping efforts but um optimizing
and leveraging efforts on resiliency. Um because it
could mean a whole lot of different measures as Commissioner
Glotfelty mentioned, I mean, it could mean hardening
the transmission system, but it could also mean adding
a redundant transmission system, operation center if
one goes down. And so there's a lot of different ways
to look at it. And um, but I do think this is
great and it's important that we continue to look at
this very important issue and
I have two votes, I think I had three. So you got
mine and I think there was another important point
that was made and that is that it's not always just
physical assets, right? And so I would hope that in
the plan that they're developed that we think not just
about the physical asset, but also the opportunities
through operations and all of the technology that's
now available. And I think if Chuck is here, we should
say cyber as well is an important risk and hopefully
that is one that will be discussed as well. It can't
be one that's too visible, but uh clearly it uh it's
a risk that uh you know, is being addressed and will
uh perhaps have a role in these forms. I will entertain
a motion to approve the proposal for publication. Um
consistent with Commissioner McAdams memo, I have a
motion and a second all in favor say I I motion passes
chairman if I if I can make sorry as I was listening
to this discussion that it really emphasized in my
mind how important defining these events is. And so
I just wanted to make a note to commenters who are
going to be comic on this. We put in a definition of
resiliency event in this. And you know, whenever you're
defining a concept as important as this blind, it's
kind of scary. So I I just want to, what we think
we were doing here was defining it broadly so that
it covered weather events, cyber events, and physical
events. But also we put in language about low frequency
high impact event. And we clarified that not primarily
associated with resource adequacy or delivering power
to Load. And so that that was an attempt to distinguish
resiliency from reliability, which is sort of related
And that was also an attempt to distinguish resiliency
on the transmission level from sort of the resource
adequacy thing. But if the words that we used in terms
of low frequency I impact or whatever are, are gonna
be viewed as constraining, what should be a valuable
tool in the resiliency tool kit I that making sure
we get those words right so that the plans are not
unduly restricted is important. So I in particular
welcome comments on the definition of resiliency event
um because it's a new definition and so I, I don't
want it to tie anybody's hands later on. Ok, thank
you.
Um (item:34:Texas Backup Power Package Advisory Committee Rulemaking) Next up is item number 34 project number 55407.
The commission's rule making for the Texas Backup Power
Package Advisory Committee, Sheila, do we have anyone
from the public signed up to speak on item number 34
No, ma'am. Ok, David Gordon with uh PUC staff is here
Um David, would you please provide a brief overview
of the proposal for publication? Yes, thank you chair
Jackson and good afternoon Commissioner David Gordon
with commission staff. Uh This is staff's proposal
of new rule 25.5 15 which would establish the Texas
Backup Power Package Advisory Committee. Um This satisfies
a requirement under SB2627 which is the Texas Energy
Fund programs. Importantly, this committee will advise
the commission on uh procedures and criteria to use
in making loans and grants under that program. I want
to clarify two bits of information on this rule. First
of all, um this is a distinct advice committee from
the legislative advisory committee that will be impaneled
to advise on the loan and grant program in sub chapter
a of chapter 34. Um And then second, this advisory
committee will only make recommendations for criteria
and procedures on the loan and grants programs. They
are not going to make recommendations on individual
projects that come up and application form. Um This
rule is going to allow the executive director to uh
select the members of the advisory committee um And
then they will deliver reports as we anticipate um
in October of next year. Um And before I open myself
up to any questions, I just want to thank Floyd Mac
uh and Connie for their help on this one. That's it
over
and commissioners just real quickly. I would add that
the process we've envisioned for. This is very similar
to what we did for Turk. The process that you approved
for me to appoint Turk commission members.
You give any thoughts on this one. (item:34:Motion to adopt proposal) I would move to
adopt the proposal for publication. I have a 2nd 2nd
all in favor. Say I I motion passes.
I don't have anything for items 35 or 36.
Uh (item:37:Information Related to the SPP Regional - Commissioner McAdams) Next up is item 37. Our project regarding information
related to the Southwest Powerful Regional State Committee
Um Sheila, do we have anyone from the public side that
to speak on item 37 ma'am? Ok. Commissioner Mc Adams
could you please provide us with an update? Absolutely
Thank you, madam, chair members uh last week. Um losing
track of time, but I believe it was last week, September
7th and eighth, uh Southwest Power Pool, organized
a resource Adequacy summit held in Dallas uh it was
well attended, we had over 150 in person attendees
Uh uh Commissioner Mark Christie was one of the uh
headline attendees as well as Nr Ceo Jim Robb. Um They
let off the summit with a panel discussion for which
I was able to ask some questions as well as others
Uh I, I thought the takeaway from that panel discussion
was extremely enlightening. Um F has divided opinions
on um II I think it's fair to say has divided opinions
on the scope and capabilities of F to manage a fully
integrated national grid system. Um And, and what that
scope should ultimately look like. Um But they, they
are aware that there's an interest to see a more assertive
fork in um in opining and urging uh systems to make
the grids more interconnected uh and integrated Jim
Robb had uh fascinating answers to some questions about
the scope of NR um I actually pressed him uh as you
know, I I sort of set him up in a series of
questions on what he believed no's role was. Um And
I assumed that they were sort of like the chief architect
or engineer of the bolt power system uh under the Federal
Power Act. Um Jim said, no, we see ourselves more of
an advisory role um which I thought given everything
that we're talking about here, um the security of the
bolt power system and uh and the, the distribution
systems under that, I, I thought that was fascinating
um especially in light of weatherization and all the
other challenges that we're trying to overcome right
now. Uh He did say that um and this was, this was
thought provoking because I, I pressed him on the capabilities
of the distribution system and uh the resiliency um
segmentation aspects of it, how, how he views that
as it relates to the bulk power system, he's like,
and, and, and I think Christie took a more narrow view
of, of how that can truly interact. But uh Jim Robb
of Nr said, no, we are, we are seeing that the distribution
system has inordinate effect on the bulk power system
And so therefore, we must watch very closely what is
being interconnected at distribution, what types of
technologies they're keenly sensitive as ERCOT has
alluded to, to inverter based technologies that are
coming in and how resilient they are. Um It, it was
a, it was a fantastic summit. Um Many urged uh either
Southwest Power Pool or NR to have another summit,
especially in light of several of the grids um evaluating
the efficacy of their reliability standards and potential
replacement. Um You know, there, there's, there's a
strong prospect that something could be organized next
spring. Uh This gathering took in um stakeholders,
we had Dan Wood uh appear from ot and I was shocked
because it was right after our e a two moment and he
drove uh drove up early that morning and was able to
speak. Ultimately, um a lot of the grids S OS PP, all
others are learning from ERCOT experience. Uh They're
trying to define what define the challenges associated
with experience and how to overcome them in their own
system uh under their own market designs. And uh II
I tell you, it was, it was a great two days. The
real team, the resource advocacy and leadership team
met uh the day after the summit concluded and we took
up performance based accreditation and expected Load
carrying capabilities of all resources for which we're
trying to cobble together a consistent proposal for
F to consider next spring. But that will provide the
foundation for SPPS, look at their reliability standard
and the inputs of that review. Um It, it has required
a great deal of compromise especially to uh solve assertions
that um resources are being treated equitably and in
a nondiscriminatory manner. These are all challenges
that we have to overcome in our own laws. Um But I
I think we're on a good path. It was uh it was
fascinating two days happy to answer any questions
But um I think we've all engaged with our f uh counterparts
Commissioner Christie was sympathetic in that um in
terms of Texas, uh Texas will come in under f jurisdiction
when they're ready to. Um that, that was encouraging
I didn't press him on that. He brought it up. Um But
uh it, it, it was good to share insights with our counterparts
in the rest of the country. And um it, it also highlighted
that we're not alone. Um But we're, we're all moving
in the same direction. It's a question of how fast
I'm glad that that summit went. Well, I know you're
part of the leadership team, put it together. I think
it's great to have you lead that effort. I hope more
more are needed. They're clearly needed. We need to
get everybody together more often, especially in the
Midwest. Um I think the Federal Federal vision, at
least with the current administration is to make the
Midwest the bread basket of renewable energy production
And it's a question of how to make these systems work
out, work within that uh under that overarching policy
and then move that power to the Load centers of the
east. Um Gonna be a lot of debate about that. Uh My
was uh they had some interesting thoughts so Aubrey
Uh Yeah. Yeah. Um He, he almost, I and I think it
was an inadvertent uh assertion that our policy on
um interconnection prioritization for dispatch was
discriminatory in nature. And I I assuage that concern
um in that we had worked a lot to try to solve
the, the problem of any type of uh perception that
it was discriminatory and that uh get aligned with
again, the financial and technical commitment to an
actual project to move it along. And II, I would take
issue with the fact that uh our interconnection queue
goes a heck of a lot quicker than
he failed to bring that up so they could get. Thank
you. It's so important. We have a seat at the table
And so I really appreciate the efforts of everyone
who's serving on all of the various committees representing
Texas. Um I don't have anything on 38 39 or 40 unless
y'all do item 41 will not be taken up. I don't have
anything on item 42. (item:43:Sunset Advisory Commission, operating budget, strategic plan - Thomas Gleeson) Next up is item number 43. Our
standing item or agency administrative issues. Sheila
do we have anyone from the public signed up to speak
on item 43? No, ma'am. Ok. Thomas, do you have an update
for us? Yes, ma'am. Thank you madam, chair and commissioners
Three things to update you on today. First, regarding
the Texas Energy Fund, um, as you know, that was created
under Senate Bill 2627. Last session, it will be up
for a vote to the voters of Texas in November. But
because of the short timelines, we have to actually
complete all the work, we have to get started before
that vote in anticipation of having to do the work
So, uh the first thing I want to update you on is
we're gonna create a website to help keep the public
and the legislature informed of our activities on this
I anticipate that the website will go live tomorrow
It will be accessible through our home page on the
PUC website. Um One thing that I've been insistent
on and um I think is the direction from the legislature
is we have to provide people with a timeline. So we
are going to develop a timeline. It will be updated
as necessary, it will be on that web page so that everyone
can see our progress for all major milestones related
to that fund. Secondly, we are going to do a workshop
on September 21st. The, the goal of that workshop really
is to get input as we develop our rules and the applications
for the different programs in there. But it's open
to anyone who wants to come and provide input to us
It will also be broadcast on Texas admin just like
our open meetings are I would ask that uh suggested
discussion topics and questions for the workshop be
submitted by September 15th in project number 54999
And we'll use that information and finalize an agenda
for the workshop on September 18th. So no questions
on that. The second thing uh in response to a Thomas
what, what was the, what's the website domain? What's
the? So um I don't know exactly what the, what the
uh URL is gonna be but it'll be we'll highlight it
on our home page. So it'll be easy to find for anyone
I mean, like I said, it should be up tomorrow.
So in response to a discussion with Commissioner Glotfelty
last open meeting, we have opened project 55421, the
Texas advanced nuclear reactor working group for documents
to be placed there. And I believe Commissioner Glotfelty
plans to file a memo to provide more context and details
around that issue. I would just encourage folks to
continue to look at that docket number. There will
be meeting notices, other information that will be
filed through that docket and I appreciate the staff
getting that docket set up. Yes, sir. And finally a
note of very good news for one of our staff. Uh Barksdale
we I nominated him for the Governor's Executive development
program which is probably the most selective uh training
program in the state for state employees. And uh he
was selected for the upcoming class, so we're very
excited for it.
He looks very excited that I called him, teach him
how to be a better enforcer. That's all I have this
morning madam chair. Ok. Thank you very much. I don't
have anything for the remainder of the agenda and unless
y'all do, um, there is nothing for a closed session
there being no further business to come before the
commission. This meeting of the Public Utility Commission
of Texas is hereby adjourned at 12 30.