WEBVTT

00:00:08.819 --> 00:00:11.550
(item:0:Chairwoman Jackson calls meeting to order) Good morning. This meeting of the Public Utility Commission

00:00:11.560 --> 00:00:14.069
of Texas will come to order. To consider matters that

00:00:14.079 --> 00:00:16.620
have been duly posted with the Secretary of State for

00:00:16.629 --> 00:00:20.500
November 30, 2023. For the record, my name is Kathleen

00:00:20.510 --> 00:00:23.620
Jackson and I'm joined by Will McAdams, Lori Cobos

00:00:23.629 --> 00:00:27.568
and Jimmy Glotfelty. (item:0:Chairwoman Jackson honors former ERCOT CEO/President Brad Jones) I'd like to take a moment to honor

00:00:27.579 --> 00:00:31.388
and remember Brad Jones, former ERCOT President and

00:00:31.399 --> 00:00:35.500
CEO. He passed away Wednesday, November 8th with his

00:00:35.509 --> 00:00:38.539
family at his side. On behalf of all of us at the

00:00:38.548 --> 00:00:41.728
Public Utility Commission of Texas. We're deeply saddened

00:00:41.740 --> 00:00:46.908
by Brad's passing. We're forever grateful for his selflessness

00:00:46.918 --> 00:00:50.179
and tireless leadership at ERCOT following the February

00:00:50.189 --> 00:00:55.240
2021 Winter Storm. Brad took on an incredibly difficult

00:00:55.250 --> 00:01:00.228
task with great enthusiasm and urgency. He immediately

00:01:00.240 --> 00:01:02.929
rolled up his sleeves working to strengthen the Texas

00:01:02.939 --> 00:01:06.519
grid, re-establish confidence in ERCOT and speak to

00:01:06.528 --> 00:01:09.528
Texans frankly and honestly about our State's power

00:01:09.540 --> 00:01:12.799
needs. Our thoughts and prayers are with Brad's family

00:01:12.808 --> 00:01:16.439
during this time of loss. We thank Brad for his service

00:01:16.448 --> 00:01:20.400
to Texas. I wonder if my other fellow Commissioners

00:01:20.409 --> 00:01:23.620
would like to say anything. I'd like to say. (item:0:Commissioner McAdams honors Brad Jones) Brad did

00:01:23.629 --> 00:01:26.980
great service to the state and under extraordinary

00:01:26.989 --> 00:01:32.000
circumstances. He uh, he gave it his all and uh it's

00:01:32.010 --> 00:01:35.959
all we can ask of any Texan. And uh he came back

00:01:35.969 --> 00:01:39.448
in from the sidelines, um brought the organization

00:01:39.459 --> 00:01:44.939
together. Helped us pick ourselves up and uh make things

00:01:44.948 --> 00:01:50.838
better. And I uh Brad's in a better place. He will

00:01:50.849 --> 00:01:51.359
be missed.

00:01:52.879 --> 00:01:56.260
(item:0:Commissioner Glotfelty honors Brad Jones) Yeah, I would say many of us in this room have known

00:01:56.269 --> 00:01:59.099
him for a long, long time since the restructuring days.

00:01:59.109 --> 00:02:03.439
And um you know, there were a few that were um uh

00:02:03.448 --> 00:02:07.719
that could bridge the divide between technical engineering,

00:02:07.730 --> 00:02:11.929
policy, Legislative language. And he could, and he could

00:02:11.939 --> 00:02:15.110
do it fluently and he could do it with ease. And uh

00:02:15.118 --> 00:02:18.550
we will miss that. Obviously, he came in and helped

00:02:18.558 --> 00:02:22.189
after Winter Storm Uri. Which in my view, there was

00:02:22.199 --> 00:02:26.308
zero other choice other than Brad Jones at the time.

00:02:26.969 --> 00:02:31.349
And it clearly he's done a great service and he will

00:02:31.360 --> 00:02:33.479
be missed. By I know everybody here at this Commission

00:02:33.490 --> 00:02:36.889
and ERCOT. But um you know, my prayers are with his family

00:02:36.899 --> 00:02:40.099
as well. (item:0:Commissoner Cobos honors Brad Jones) Yes and I just echo everything that's just said.

00:02:40.110 --> 00:02:43.990
My prayers are with his family and his, his many friends.

00:02:44.000 --> 00:02:46.139
And, you know, we like Jimmy just said. You know, we've

00:02:46.149 --> 00:02:48.000
known Brad for a very long time in a lot of different

00:02:48.008 --> 00:02:51.139
capacities throughout her career. And, you know, he's

00:02:51.149 --> 00:02:53.618
mostly remembered right now because of stepping in

00:02:53.629 --> 00:02:55.649
you know, to help ERCOT when no one else will. At

00:02:55.659 --> 00:02:57.689
a time of great need for our State. And, you know,

00:02:57.699 --> 00:03:00.500
we will always be tremendously thankful for that service.

00:03:00.508 --> 00:03:03.580
But he has been a tremendous contributor to our

00:03:03.588 --> 00:03:09.139
industry for many years. His uh charisma, his intellect

00:03:09.639 --> 00:03:12.599
and um humor will always be missed. I think I made

00:03:12.610 --> 00:03:14.288
his day, when I finally told him he reminded me of

00:03:14.300 --> 00:03:18.909
Matthew McConaughey. And uh I don't think he was ever

00:03:18.919 --> 00:03:21.169
as happy as I've ever seen him, and he was always seemed

00:03:21.179 --> 00:03:25.399
to be very happy. So, you know, we will miss Brad.

00:03:25.439 --> 00:03:29.270
We'll miss his charisma, his charm, his intellect,

00:03:29.278 --> 00:03:33.069
his contributions to our industry. And thoughts and

00:03:33.080 --> 00:03:36.349
prayers are with his family during this time of loss.

00:03:38.939 --> 00:03:41.679
(item:0:Chairwoman Jackson recognizes Commissioner Glotfelty's new appointment) Next, I'd like to recognize uh Commissioner Glotfelty

00:03:41.689 --> 00:03:44.500
He was recently appointed to the National Association

00:03:44.639 --> 00:03:48.929
of Regulatory Commissioners uh new gas electric working

00:03:48.939 --> 00:03:52.860
group called GEAR, Gas Electric Alignment for Reliability.

00:03:52.939 --> 00:03:56.854
Along with representatives of just 5 other states. This

00:03:56.865 --> 00:04:00.145
new working group is embarking on a 15 month initiative.

00:04:00.153 --> 00:04:02.824
To better harmonize the gas and electric industries.

00:04:03.044 --> 00:04:06.764
To improve the reliability of both systems. So congratulations

00:04:06.774 --> 00:04:09.554
Jimmy and I know you will represent Texas well. Thank

00:04:09.594 --> 00:04:09.784
you. 

00:04:13.794 --> 00:04:17.170
Congratulations Jimmy. (item:0:Chairwoman Jackson recognizes former IMM, Carrie Bivens) I'd also like to extend a heartfelt appreciation

00:04:17.178 --> 00:04:20.689
to Carrie Bivens who has left her role as the Independent

00:04:20.699 --> 00:04:23.709
Market Monitor Director for the ERCOT marketplace.

00:04:23.738 --> 00:04:27.149
After serving in this role for 3 1/2 years. We wish her

00:04:27.160 --> 00:04:30.500
the best and appreciate her expertise and input as

00:04:30.509 --> 00:04:33.588
a valued member of the electric industry community.

00:04:35.329 --> 00:04:38.819
(item:0:Commissioners recognize Carrie Bivens achievements as IMM) I would like to second that. I think Carrie was not afraid

00:04:38.829 --> 00:04:42.410
to give her points. Although they weren't always in

00:04:42.420 --> 00:04:45.548
line with everybody else's. And in this dynamic system

00:04:45.559 --> 00:04:48.829
we have to have data points more than just one. And

00:04:48.838 --> 00:04:50.838
she was bold enough to step out there. And I'm very

00:04:50.850 --> 00:04:55.709
appreciative of that. I echo that Madam Chair. This

00:04:55.720 --> 00:04:58.910
is a tough role. That is a tough role in responsibility

00:04:58.920 --> 00:05:02.230
right now. But it's very important, it's crucial. And

00:05:02.238 --> 00:05:06.088
she uh she embraced that, that mantra of independence.

00:05:06.199 --> 00:05:12.309
And, and did so um that by maintaining credibility and

00:05:12.319 --> 00:05:15.500
enhancing it with key policymakers. And that's something

00:05:15.509 --> 00:05:18.600
that is invaluable right now. So we appreciated or

00:05:18.608 --> 00:05:20.778
I certainly appreciated her service. Because I believe

00:05:20.790 --> 00:05:23.290
it was, it was more than just a contract. It was service

00:05:23.298 --> 00:05:27.988
as well. So I applaud Carrie. Yeah. I echo all the sentiments.

00:05:28.399 --> 00:05:30.738
I really appreciate Carrie's hard work over the last several

00:05:30.750 --> 00:05:33.798
years. I mean, her hard work started I'm sure when

00:05:33.809 --> 00:05:37.449
she went to work for Potomac at, at the as ERCOT IMM.

00:05:37.459 --> 00:05:40.389
But certainly with Winter Storm Uri and our market

00:05:40.399 --> 00:05:43.069
reform discussions. Those are tough issues. They're

00:05:43.079 --> 00:05:48.238
complicated and she was a exemplified, very strong

00:05:48.250 --> 00:05:51.528
will. To stand behind her positions and whether we agree

00:05:51.540 --> 00:05:53.809
or not with all of Carrie's positions. The point is she

00:05:53.819 --> 00:05:57.488
made her, she made her independent voice heard. And

00:05:57.500 --> 00:06:01.048
it's important um that even if we don't agree, that

00:06:01.059 --> 00:06:04.298
you hear um perspectives. And that's what the IMM is

00:06:04.309 --> 00:06:07.069
there for. And I really appreciate all of her hard

00:06:07.079 --> 00:06:10.369
work and all of her feedback on these issues um over

00:06:10.379 --> 00:06:14.619
the last several years. Very good. Many thanks to Carrie.

00:06:15.100 --> 00:06:17.759
(item:0:Chairwoman Jackson lays out the planning purpose for today’s agenda) For planning purposes, we will go into Closed Session

00:06:17.769 --> 00:06:21.420
as close to 11:30 as possible. If we have not finished

00:06:21.428 --> 00:06:25.079
the Agenda by then we'll recess around 11:30. And come back

00:06:25.088 --> 00:06:27.069
after Closed Session to finish the remainder of the

00:06:27.079 --> 00:06:30.769
agenda and work through lunch. (item:0:Chairwoman Jackson lays out instructions for Public Comments) Public Comments for

00:06:30.778 --> 00:06:33.428
general matters will be taken up when we get to Section

00:06:33.439 --> 00:06:37.470
2, Item No. 19. Public Comments related to a specific

00:06:37.480 --> 00:06:40.588
agenda item will be heard when that item is taken up.

00:06:40.829 --> 00:06:44.278
Speakers will be limited to 3 minutes each. Commenters

00:06:44.290 --> 00:06:46.689
should not approach the table unless oral argument

00:06:46.699 --> 00:06:50.509
has been granted or have been invited by a Commissioner.

00:06:51.488 --> 00:06:53.889
Shelah, will you please walk us through the Consent

00:06:53.899 --> 00:06:57.889
Items on today's Agenda? Yes. (item:0.1:Shelah Cisneros with Commission Counsel lays out Consent Agenda) Good morning Commissioners.

00:06:57.899 --> 00:07:00.480
By individual ballot, the following items were placed

00:07:00.488 --> 00:07:04.670
on your Consent Agenda. Items 1-7, 9-15,

00:07:04.678 --> 00:07:10.220
17 and 18. (item:0.1:Chairwoman Jackson asks for motion to approve items on Consent Agenda) I'll entertain a motion to approve the

00:07:10.230 --> 00:07:13.980
items just described by Shelah. So moved. Second. I have a motion and 

00:07:13.988 --> 00:07:19.420
a second. All in favor, say aye. Aye. Motion passes. Items

00:07:19.428 --> 00:07:23.119
1-7 have been Consented. First up is

00:07:23.129 --> 00:07:25.838
Item No. 8. Shelah, will you please lay out

00:07:25.850 --> 00:07:29.819
this Item? Yes, ma'am. (item:8:Application of Entergy Texas to revise fixed fuel factor) Item No. 8 is Docket 

00:07:29.829 --> 00:07:35.160
No. 54674. This is the Application of Entergy Texas

00:07:35.488 --> 00:07:40.108
Inc., to revise fixed fuel factor. Before you is a proposal

00:07:40.119 --> 00:07:45.009
for decision from SOAH. Entergy Texas filed exceptions. Commission

00:07:45.019 --> 00:07:47.858
Staff and OPUC also filed exceptions to the proposal

00:07:47.869 --> 00:07:51.309
for decision. The SOAH ALJ filed a letter revising the

00:07:51.319 --> 00:07:53.980
proposal for decision. A Commission Counsel memo was

00:07:53.988 --> 00:07:57.250
filed recommending changes to the PFD. And Chairman

00:07:57.259 --> 00:08:00.678
Jackson filed a memo in this proceeding. (item:8:Commissioner McAdams lays out his memo) I filed a

00:08:00.689 --> 00:08:03.480
memo in this docket recommending that Entergy Texas

00:08:03.488 --> 00:08:06.459
application be approved. But for reasons other than

00:08:06.470 --> 00:08:09.709
those set out in the proposal for decisions. Uh do

00:08:09.720 --> 00:08:12.910
we have any thoughts on this one? No, Madam Chair. Thank

00:08:12.920 --> 00:08:15.350
you for stepping up on this, I really appreciate it.

00:08:15.358 --> 00:08:17.829
(item:8:Commissioner Cobos thoughts on memo) I usually get put on the hot seat for MISO matters

00:08:17.838 --> 00:08:19.959
and so you took the weight off me on this very busy

00:08:19.970 --> 00:08:22.269
agenda. But you know, you're from Southeast Texas.

00:08:22.278 --> 00:08:24.819
You could step up and handle this matter too. Thank

00:08:24.829 --> 00:08:28.250
you. (item:8:Commissioner Glotfelty & McAdams thoughts on memo) I agree with what you've laid out in your memo,

00:08:28.259 --> 00:08:32.129
and fully support it. As do I, Madam Chair. (item:8:Motion to modify proposed decision concerning both memos) I would move to

00:08:32.139 --> 00:08:34.428
modify the proposal for a decision consistent with

00:08:34.440 --> 00:08:37.168
my memo and the Commission Counsel memo. Do I have

00:08:37.178 --> 00:08:40.820
a second? Second. All in favor, say aye. Aye. Motion passes.

00:08:42.438 --> 00:08:45.668
Items 9-15 have been Consented. Next up

00:08:45.678 --> 00:08:48.729
is Item No. 16. Shelah, will you please lay out

00:08:48.739 --> 00:08:52.918
this Item? Yes, ma'am. (item:16:Application of Oncor Electric Delivery Co., LLC to amend its
DCRF) Item number 16 is Docket No. 

00:08:52.928 --> 00:08:57.408
55525. This is the Application of Oncor Electric Delivery

00:08:57.418 --> 00:09:01.500
company LLC to amend its distribution cost recovery

00:09:01.509 --> 00:09:04.139
factor. So at the outset, let me just make things a

00:09:04.149 --> 00:09:06.599
little bit easier for the Court Reporter. And say that

00:09:06.609 --> 00:09:10.109
we may be using the acronym DCRF for Distribution

00:09:10.119 --> 00:09:13.469
Cost Recovery Factor. The Commission requested briefing

00:09:13.479 --> 00:09:17.038
from the parties on a single threshold issue before

00:09:17.048 --> 00:09:20.109
you are briefs from the Alliance of Oncor Cities, the

00:09:20.119 --> 00:09:23.210
Steering Committee of Cities served by Oncor, the Alliance

00:09:23.219 --> 00:09:27.190
for Retail Markets, TIEC, Commission Staff and Oncor.

00:09:27.710 --> 00:09:31.168
The issue that was briefed is the following: For DCRF

00:09:31.178 --> 00:09:36.399
applications filed on or after June 18, 2023. All

00:09:36.489 --> 00:09:39.239
party is entitled to an opportunity before a hearing

00:09:39.250 --> 00:09:42.908
on the merits in DCRF proceedings. That is the issue

00:09:42.918 --> 00:09:43.678
before the Commission.

00:09:46.658 --> 00:09:50.918
(item:16:Chairwoman Jackson's thoughts on the order) The Legislature recently amended the DCRF statute imposed

00:09:50.928 --> 00:09:55.099
a 60 day deadline on DCRF proceedings. However, no

00:09:55.109 --> 00:09:58.288
legal authority expressly provided a right to a hearing

00:09:58.298 --> 00:10:01.808
in DCRF proceedings due to the new statutory deadline

00:10:01.820 --> 00:10:05.729
And because DCRF proceedings are interim rate adjustments

00:10:05.739 --> 00:10:09.048
rather than rate changes, the opportunity for a hearing

00:10:09.058 --> 00:10:12.479
will occur in the next base rate proceeding. I would

00:10:12.489 --> 00:10:14.969
ask that an order on briefing issues be drafted in

00:10:14.979 --> 00:10:17.479
accordance with our discussion. Are there any thought?

00:10:18.979 --> 00:10:24.190
So I'm happy to go. (item:16:Commissioner Glotfelty's thoughts on the order) I agree with this with what you

00:10:24.200 --> 00:10:29.340
say stubbornly. Because I think hearings ought to be

00:10:29.460 --> 00:10:35.109
available to as often as we can. But things like this

00:10:35.119 --> 00:10:36.509
are fairly unique,

00:10:38.080 --> 00:10:41.379
especially because we would have to conduct these hearings

00:10:41.479 --> 00:10:43.950
as the Commission. We would have to do them at least

00:10:43.960 --> 00:10:48.080
twice a year for every DCRF. For every utility that's

00:10:48.090 --> 00:10:51.820
filing a DCRF modification. So that means at least eight

00:10:51.830 --> 00:10:56.080
hearings a year. Eight staffs all the time for us,

00:10:56.090 --> 00:10:58.678
our staffs and the Commission Staff. To me, that doesn't

00:10:58.690 --> 00:11:03.009
seem logical. But what we need to do is we need to

00:11:03.125 --> 00:11:07.094
make sure that these DCRF issues remain front and center

00:11:07.104 --> 00:11:09.803
when we have base rate proceedings. And that they don't

00:11:09.815 --> 00:11:12.625
get buried because they are important. These numbers

00:11:12.634 --> 00:11:18.104
will grow. And consumers ought to be, ought to have

00:11:18.114 --> 00:11:20.904
the comfort that these numbers are going to be scrutinized.

00:11:21.053 --> 00:11:24.293
You know, throughout the time of the rights, so. And

00:11:24.303 --> 00:11:28.979
and I agree with that. (item:16:Commissioner McAdams' thoughts on the order) So a little bit of history.

00:11:28.989 --> 00:11:33.820
The DCRF has been hotly debated, argued over um

00:11:33.830 --> 00:11:39.529
haggled over for a long time and especially in the

00:11:39.538 --> 00:11:43.109
Legislature. And at the end of the day, the overarching

00:11:43.119 --> 00:11:46.330
policy around DCRF is an expedited recovery mechanism 

00:11:46.340 --> 00:11:50.129
for our utilities. To timely deploy capital to get plan

00:11:50.139 --> 00:11:52.710
in service to support distribution level needs.

00:11:54.389 --> 00:12:00.788
The, the absence of a hearing requirement is logical

00:12:00.798 --> 00:12:06.109
in that they want timely recovery. The uh, I had a hand

00:12:06.119 --> 00:12:09.979
in facilitating negotiations on trying to harmonize

00:12:09.989 --> 00:12:13.500
what we're doing through these expedited recovery mechanisms

00:12:13.509 --> 00:12:18.469
in Senate Bill 735 in 2015. Which put our investor

00:12:18.548 --> 00:12:23.340
owned utility TDSPs on a comprehensive base rate schedule

00:12:23.969 --> 00:12:27.070
And that's every four years. And in doing so, that

00:12:27.080 --> 00:12:29.489
was the covenant between the utilities and the consumers

00:12:29.500 --> 00:12:33.529
is that they would timely recover capital cost through

00:12:33.538 --> 00:12:35.558
these expedited recovery mechanisms. But there would

00:12:35.570 --> 00:12:38.190
be a full-blown rate case at the end of that schedule

00:12:38.200 --> 00:12:42.649
to where prudency would be reviewed to where all these

00:12:42.658 --> 00:12:45.279
issues would be litigated. And ultimately, if it was

00:12:45.288 --> 00:12:48.369
found deficient funds would be chewed up and clawed

00:12:48.379 --> 00:12:54.570
back. And, and so that, that's the system. And I believe

00:12:54.580 --> 00:12:58.889
what your position is Madam Chair is consistent with

00:12:58.899 --> 00:12:59.519
the policy.

00:13:01.830 --> 00:13:05.330
(item:16:Commissioner Cobos' thoughts on the order) I'm in agreement with the um proposed process going

00:13:05.340 --> 00:13:10.250
forward um given the legislative um direction that

00:13:10.259 --> 00:13:13.168
we got this past session in the 60 day timeline and

00:13:13.178 --> 00:13:16.769
all of the um you know, surrounding impacts that would

00:13:16.779 --> 00:13:20.690
mean for processing those cases. And I, I do think

00:13:20.700 --> 00:13:23.928
that along with um instructing commission advising

00:13:23.940 --> 00:13:27.099
to draft an order on, on briefing issues uh consistent

00:13:27.109 --> 00:13:30.000
with our discussion that we asked that staff open up

00:13:30.009 --> 00:13:33.320
a rule making project to prioritize the implementation

00:13:33.330 --> 00:13:37.889
of Senate Bill um 1015. And, and um I know we got

00:13:37.899 --> 00:13:39.450
a lot on our plate, but I think we got to get

00:13:39.460 --> 00:13:43.298
this process in place so that um we can continue to

00:13:43.308 --> 00:13:46.450
uh as a Commission process, these DCRF cases that

00:13:46.460 --> 00:13:49.259
are coming in twice a year and these very short expedited

00:13:49.849 --> 00:13:53.428
uh time frame 60 day deadline. But also because I,

00:13:53.440 --> 00:13:57.989
I think as we address, um you know, in that role, the

00:13:58.000 --> 00:14:00.668
processing of the DCRF cases, there's, there's two

00:14:00.678 --> 00:14:02.869
types of DCRFs investments that we're looking at now

00:14:02.879 --> 00:14:04.928
right? Uh distribution investment. So you've got the

00:14:04.940 --> 00:14:08.779
traditional uh dis distribution investment cost to

00:14:08.788 --> 00:14:13.479
recoup through DCRF proceedings. But now we have the

00:14:13.489 --> 00:14:18.200
um on the mobile DD uh investment costs that are being

00:14:18.210 --> 00:14:21.009
processed through DCRF proceedings. And so we've got

00:14:21.019 --> 00:14:24.340
to provide some policy direction and how we'll handle

00:14:24.349 --> 00:14:27.719
those two types of proceedings going forward under

00:14:27.729 --> 00:14:31.798
the DCRF umbrella. Um You know, as you've explained

00:14:31.808 --> 00:14:36.869
you know, a hearing um would not be held for traditional

00:14:36.879 --> 00:14:40.090
DCRF writers. But when you look at on site Mobile

00:14:40.099 --> 00:14:45.590
and the Legislation got passed, the, there's a reasonableness

00:14:45.599 --> 00:14:49.629
and necessity determination that would occur on those

00:14:49.639 --> 00:14:54.048
investments. So we got, we got to open the rule, implement

00:14:54.058 --> 00:14:58.808
the Legislation Senate Bill 1015. But also create

00:14:58.820 --> 00:15:00.788
a clear path forward of how we're going to process

00:15:00.798 --> 00:15:03.570
the two different types of DCRF cases going forward

00:15:04.090 --> 00:15:07.389
and provide that certainty to the utilities and the

00:15:07.399 --> 00:15:11.340
stakeholders going forward. And then specifically addressing

00:15:11.349 --> 00:15:15.178
that mobile gen individual fact set that is very unique

00:15:15.190 --> 00:15:18.109
to mobile generation. And oh, by the way, it was 2017

00:15:18.119 --> 00:15:21.570
not 2015 for Senate Bill 735. Senator Hancock could call me

00:15:21.580 --> 00:15:25.849
after this. So, uh anyway um but I, I agree. I agree.

00:15:28.570 --> 00:15:34.009
So is the motion? (item:16:Motion to direct OPDM to draft briefing order) So I would move to direct OPDM to

00:15:34.019 --> 00:15:36.779
draft a briefing order consistent with our discussion.

00:15:37.729 --> 00:15:42.330
And Staff to open a rulemaking. That request already

00:15:42.340 --> 00:15:45.590
on our schedule for the first quarter of 2024. Thank

00:15:45.599 --> 00:15:49.639
you. Great. Thank you. Second. I have a motion and a second.

00:15:49.649 --> 00:15:56.058
All in favor, say aye. Aye. Motion passes. Items 17 and 18 were Consented.

00:15:57.019 --> 00:16:00.019
We will now transition to Section 2 of our Agenda:

00:16:00.029 --> 00:16:03.840
Rules, Projects and Miscellaneous Items. So we'll give

00:16:03.849 --> 00:16:07.298
folks a few minutes to clear the room. That just came

00:16:07.308 --> 00:16:08.969
for this part of the meeting.

00:16:10.969 --> 00:16:14.979
(item:19:Chairwoman Jackson lays out instructions for General Comment) Next up is Item No. 19, General Comments for topics

00:16:14.989 --> 00:16:18.279
not specifically posted on this agenda. Speakers will

00:16:18.288 --> 00:16:21.009
be limited to 3 minutes each. Shelah, do we have

00:16:21.019 --> 00:16:24.210
anyone from the public signed up to speak? No, ma'am,

00:16:24.219 --> 00:16:27.288
no one signed up to speak. This completes Item No. 

00:16:27.298 --> 00:16:33.090
19. (item:20:Chairwoman Jackson lays out Project No. 54453 and gives thoughts on deferment) Next up is Item No. 20, Project No. 54453.

00:16:33.099 --> 00:16:36.129
This is the Commission's project for Year-End 2022

00:16:36.139 --> 00:16:39.538
Water and Sewer Utility Annual Reports. Shelah, do

00:16:39.548 --> 00:16:41.700
we have anyone from the public signed up to speak on

00:16:41.710 --> 00:16:43.418
Item No. 20? No, ma'am.

00:16:45.070 --> 00:16:48.279
PUC Staff filed a memo and yesterday we received a

00:16:48.288 --> 00:16:51.779
request from Undine group to delay our consideration

00:16:51.788 --> 00:16:52.750
of Staff's memo.

00:16:54.359 --> 00:16:56.609
It would have been helpful for Undine group to have

00:16:56.619 --> 00:16:59.629
communicated its plans more than 24 hours before the

00:16:59.639 --> 00:17:02.599
Open Meeting. And to have engaged in a dialogue with

00:17:02.609 --> 00:17:06.750
rate regulation staff before this week. However, given

00:17:06.759 --> 00:17:09.410
that Undine Group has notified us of plans to file a

00:17:09.420 --> 00:17:13.000
rate case next month. I'm fine with deferring consideration

00:17:13.009 --> 00:17:16.430
of Staff's memo until January. Does this work with everyone,

00:17:17.400 --> 00:17:22.337
any thoughts? Works for me if Staff? Staff is ok with it. Great.

00:17:26.958 --> 00:17:28.698
We don't need to do a vote or anything? No action. Correct.

00:17:30.548 --> 00:17:33.979
Okay. I don't have anything on Item No. 21. (item:22:Chairwoman Jackson lays out Project No. 54589) Next up

00:17:33.989 --> 00:17:39.019
is Item No. 22, Project No. 54589. This is the

00:17:39.028 --> 00:17:41.817
Commission's rulemaking regarding its review of Chapter

00:17:41.827 --> 00:17:45.817
26, Substantive Rules applicable to Telecommunications

00:17:45.827 --> 00:17:48.409
Service Providers. Shelah, do we have anyone from the

00:17:48.417 --> 00:17:51.417
public signed up to speak on Item No. 22? No ma'am.

00:17:52.739 --> 00:17:56.759
PUC Staff filed a recommended order on adoption. David

00:17:56.769 --> 00:18:01.229
Smeltzer is here. Um David, could you please state

00:18:01.239 --> 00:18:04.439
your name for the record and then provide a brief overview

00:18:04.449 --> 00:18:07.430
of Staff's recommendation. (item:22:PUC Staff's David Smeltzer with review of Chapter 26) Sure, David Smeltzer for

00:18:07.439 --> 00:18:10.828
Commission Staff. Um, this is our review of Chapter

00:18:10.838 --> 00:18:14.380
26. And this was one of our, one of our management actions

00:18:14.390 --> 00:18:17.088
from the Sunset Commission was to do a more thorough

00:18:17.098 --> 00:18:21.500
review of rules during our regularly scheduled reviews.

00:18:21.509 --> 00:18:23.809
This is the first one that's come up. Um, this is our

00:18:23.818 --> 00:18:27.608
telecom rules and as part of this, we ended up repealing

00:18:27.618 --> 00:18:31.588
modifying or amending 48 different rules in our telecom

00:18:31.858 --> 00:18:35.078
section. And um, you know, most of the work was done

00:18:35.088 --> 00:18:37.078
by Mack. Who's hiding in the corner and refuses to take

00:18:37.088 --> 00:18:39.880
credit for anything. So everyone look and be thankful

00:18:39.890 --> 00:18:44.250
for his efforts. I, I can try and enumerate some of

00:18:44.259 --> 00:18:46.250
the changes. But I think in briefing, we covered them.

00:18:46.259 --> 00:18:48.269
There's not a whole lot of substance that change between

00:18:48.279 --> 00:18:52.564
the PFP to PFA. And I will note when you, if

00:18:52.574 --> 00:18:54.723
you don't have any questions or want a more thorough

00:18:54.733 --> 00:18:58.453
detailing of the, of the contents. I will note that

00:18:58.463 --> 00:19:00.164
we've, we've been contacted and there were, there were

00:19:00.174 --> 00:19:04.295
two typos in this giant order. And so when you approve

00:19:04.305 --> 00:19:08.434
the, if you approve this. We, we would like you to

00:19:08.443 --> 00:19:11.404
approve it and give us discretion to change those two

00:19:11.414 --> 00:19:16.318
little typos so that it reads accurately. I'm available

00:19:16.328 --> 00:19:17.910
for any questions or discussion.

00:19:19.949 --> 00:19:20.818
Look good to me,

00:19:22.709 --> 00:19:25.279
Madam Chair. Okay. Same. (item:22:Motion to approve Staff's recommendation for adoption) I would entertain a motion to approve Staff's recommendation

00:19:25.289 --> 00:19:28.598
for adoption. Consistent with the changes that Staff

00:19:28.608 --> 00:19:32.729
has proposed. I would so move. We have a motion and.

00:19:32.789 --> 00:19:38.088
Second. A second all in favor, say aye. Aye. Motion passes. I

00:19:38.098 --> 00:19:42.439
don't have anything on Item No. 23. (item:24:Chairwoman Jackson lays out Project No. 54451) Next up is Item

00:19:42.449 --> 00:19:46.539
No. 24., Project No. 54451. This is the Commission's

00:19:46.549 --> 00:19:49.910
project for Year-End 2022 Electric Utility Earnings

00:19:49.920 --> 00:19:52.500
reports. Shelah, do we have anyone from the public

00:19:52.509 --> 00:19:55.489
signed up to speak on Item No. 24? No, ma'am.

00:19:57.209 --> 00:20:00.358
PUC Staff filed a memo with a revision yesterday and

00:20:00.368 --> 00:20:03.209
as an outcome of Staff's review of the electric utility

00:20:03.219 --> 00:20:06.709
earnings reports filed for the 2022 reporting year.

00:20:06.729 --> 00:20:09.019
Staff is not recommending that the Commission require

00:20:09.029 --> 00:20:12.338
any of those utilities file an application for a comprehensive

00:20:12.884 --> 00:20:16.525
proceeding. Included in Staff's revised memo is also

00:20:16.535 --> 00:20:20.074
a summary regarding expected comprehensive rate cases

00:20:20.084 --> 00:20:22.814
over the next four years. This is an excellent resource

00:20:22.824 --> 00:20:26.375
for planning and our upcoming workload. Do we have

00:20:26.384 --> 00:20:28.074
any thoughts on this one?

00:20:30.009 --> 00:20:32.880
(item:24:Commissioner Cobos thoughts on Project No. 54451) No, I certainly appreciate the overview of um the rate

00:20:32.890 --> 00:20:35.689
cases to come. I think that's important um to understand

00:20:35.699 --> 00:20:38.739
what's coming down the pike and rate case proceedings

00:20:38.750 --> 00:20:42.239
in the next year or two. And I certainly appreciate

00:20:42.250 --> 00:20:44.880
Darryl's work in providing all this information to

00:20:44.890 --> 00:20:47.318
us so that we have a sense of where our um not

00:20:47.328 --> 00:20:52.759
only our um TDUs or IOUs, but also um the

00:20:52.769 --> 00:20:55.578
entities where we um have authority over wholesale

00:20:55.588 --> 00:20:59.689
transmission service rates, um the Munis, the Co-ops

00:21:00.449 --> 00:21:04.469
uh River Authorities. And so I appreciate the information

00:21:04.479 --> 00:21:04.588
Darryl.

00:21:09.750 --> 00:21:14.068
I'm, I'm I agree with Staff's recommendation and are

00:21:14.078 --> 00:21:17.489
supportive of the path forward. And so again, I just

00:21:17.500 --> 00:21:20.469
point everybody to the summary of expected filing dates

00:21:20.479 --> 00:21:22.789
of electric utilities comprehensive right proceedings

00:21:22.799 --> 00:21:26.189
which is something that we added to this proceeding

00:21:26.199 --> 00:21:29.118
I think would be very helpful moving forward. Thank

00:21:29.130 --> 00:21:35.660
you. (item:25:Chairwoman Jackson lays out Project No. 55562) Next up is Item No. 25, Project No. 55562.

00:21:35.739 --> 00:21:39.430
This is the Commission's project for its RFP for a contractor

00:21:39.439 --> 00:21:42.779
to manage the Texas Energy Fund programs. Shelah, do

00:21:42.789 --> 00:21:45.338
we have anyone from the public signed up to speak on

00:21:45.348 --> 00:21:49.189
Item No. 25? No, ma'am. Commission Staff filed a

00:21:49.199 --> 00:21:51.750
memo and a proposed order that would delegate authority

00:21:51.759 --> 00:21:54.640
to the Executive Director. To make an award, negotiate

00:21:54.650 --> 00:21:57.368
pricing and performance requirements and execute and

00:21:57.380 --> 00:22:00.059
administer the contract for the management of the Texas

00:22:00.068 --> 00:22:02.699
Energy Fund programs. Do you have any comments?

00:22:05.779 --> 00:22:08.828
I think they've done great work here. Expedited timeline

00:22:08.838 --> 00:22:11.150
straddle in a whole election. I think you all have

00:22:11.160 --> 00:22:16.199
done good work and thank you. Thank you. (item:25:Motion to approve the proposed order) I would entertain

00:22:16.209 --> 00:22:17.949
a motion to approve the proposed order.

00:22:20.318 --> 00:22:26.439
So moved. Do I have a second? Second. All in favor, say aye. Aye. Motion passes. (item:26:Chairwoman Jackson lays out Project No. 55182) Next

00:22:26.449 --> 00:22:30.380
up is Item No. 26, Project No. 55182. This is

00:22:30.390 --> 00:22:32.818
the Commission's rulemaking regarding the Texas Energy

00:22:32.828 --> 00:22:36.108
Fund Completion Bonus program. Shelah, do we have anyone

00:22:36.118 --> 00:22:40.118
from the public sign speak on Item No. 26. No, ma'am.

00:22:40.489 --> 00:22:44.059
PUC Staff filed a proposal for publication. We have

00:22:44.068 --> 00:22:47.989
PUC Staff here. Do you want to provide a brief overview

00:22:48.000 --> 00:22:51.078
of this proposal of publication? Yes thank you, ma'am.

00:22:51.088 --> 00:22:52.989
(item:26:PUC Staff's David Gordon on PFP new Rule 25.511) Good morning Commissioners. This is David Gordon with

00:22:53.000 --> 00:22:56.098
Commission Staff. This is a Commission Staff's proposal

00:22:56.108 --> 00:22:59.459
for publication for a new rule 25.511, which will

00:22:59.469 --> 00:23:01.930
establish the completion bonus grant program as part

00:23:01.939 --> 00:23:05.529
of the part of the Texas Energy Fund Suite of programs.

00:23:05.969 --> 00:23:08.910
The rule here is designed to accomplish three main

00:23:08.920 --> 00:23:11.539
things we want to describe who is eligible to receive

00:23:11.549 --> 00:23:14.608
a completion bonus grant. We want to establish procedures

00:23:14.618 --> 00:23:17.229
for applying for a completion completion bonus grant

00:23:17.239 --> 00:23:20.009
and the method for requesting annual grant payments

00:23:20.400 --> 00:23:23.209
And then we also want to set the performance standards

00:23:23.219 --> 00:23:27.170
that facilities will need to meet to obtain those grant

00:23:27.180 --> 00:23:30.739
payments. Um The way this rule will operate is that

00:23:30.868 --> 00:23:33.818
the approved facilities will receive a notice of eligibility

00:23:33.848 --> 00:23:37.439
that will authorize them to receive data from ERCOT

00:23:37.449 --> 00:23:40.650
on how their facility has performed. Then every year

00:23:40.660 --> 00:23:42.608
for the 10 year period for which they can receive a

00:23:42.618 --> 00:23:46.239
payment, they will submit that data and uh support

00:23:46.250 --> 00:23:49.719
their request for a payment. Along with the proposed

00:23:49.729 --> 00:23:53.930
rule text, we've also asked specific questions um about

00:23:53.939 --> 00:23:56.900
facility arrangements. And so we'd like the the feedback

00:23:56.910 --> 00:24:00.969
from commenters when talk about the rule text as well

00:24:01.549 --> 00:24:04.719
I have a list of people who I want to thank

00:24:04.729 --> 00:24:07.519
for this because this is a little bit new for us and

00:24:07.529 --> 00:24:10.400
these people really did help the rule become a better

00:24:10.410 --> 00:24:13.939
proposal for comment. And those people are Ramya Ramaswamy,

00:24:13.949 --> 00:24:17.189
Floyd Walker, Mac Arthur who worked on everything for

00:24:17.199 --> 00:24:20.439
this meeting I think. Mariah Benson and uh especially

00:24:20.449 --> 00:24:24.390
Tyler Nicholson for helping me with math that I don't

00:24:24.400 --> 00:24:28.959
do very well with. Staff recommends uh approval of

00:24:28.969 --> 00:24:31.479
this proposal. But um I'm happy to answer any questions

00:24:31.489 --> 00:24:32.549
that you all may have too.

00:24:36.299 --> 00:24:38.920
Look good to me. I don't have any questions. Thank

00:24:38.930 --> 00:24:40.699
you for all your hard work to you and the team you

00:24:40.709 --> 00:24:44.348
just um listed. Thank you so much for your hard work.

00:24:44.759 --> 00:24:47.598
(item:26:Motion to approve PFP) I would entertain a motion to approve this proposal

00:24:47.608 --> 00:24:51.568
for publication. So moved. Second. I have a motion

00:24:51.578 --> 00:24:56.489
and a second. All in favor, say aye. Aye. Motion passes. (item:27:Chairwoman Jackson lays out Project No. 55826) Next

00:24:56.500 --> 00:25:00.660
up is Item No. 27, Project No. 55826. This is

00:25:00.670 --> 00:25:03.039
the Commission's rulemaking regarding the Texas Energy

00:25:03.049 --> 00:25:06.709
Fund In-ERCOT Generation Loan program. Shelah, do we

00:25:06.719 --> 00:25:09.118
have anyone from the public signed up to speak on Item

00:25:09.130 --> 00:25:13.150
No. 27. No, ma'am. PUC Staff filed a memo and

00:25:13.160 --> 00:25:16.838
a revised proposal for publication. We have PUC Staff

00:25:16.848 --> 00:25:20.489
here. Could you state your name for the record and

00:25:20.500 --> 00:25:24.098
um give us an overview of your memo and the revised

00:25:24.108 --> 00:25:26.979
proposal for publication? Yes. (item:27:PUC Staff's Allison Fink on PFP creating Section 25.510) Good morning, Commissioners.

00:25:26.989 --> 00:25:31.239
Alison Fink with Commission Staff. This proposal

00:25:31.250 --> 00:25:36.500
for publication will create new Section 25.510 and

00:25:36.509 --> 00:25:39.608
establish the Texas Energy Fund In-ERCOT Generation loan

00:25:39.618 --> 00:25:43.430
program. These are low interest loans for new or upgraded

00:25:43.439 --> 00:25:46.400
dispatchable electric generating facilities within

00:25:46.410 --> 00:25:50.500
the ERCOT region and it's a loan application. It's

00:25:50.969 --> 00:25:54.039
the rule structure is what you'd expect from a loan

00:25:54.049 --> 00:25:58.309
application outlines eligibility of applicants.

00:25:58.318 --> 00:26:00.939
What they, what documentation they'll need to provide

00:26:01.209 --> 00:26:04.729
as part of their application, the evaluation criteria

00:26:04.779 --> 00:26:06.989
by which the Commission Staff will determine which

00:26:07.289 --> 00:26:11.709
which applications deserve loans um or should be awarded

00:26:11.719 --> 00:26:16.029
loans I should say. Ongoing obligations for those successful

00:26:16.039 --> 00:26:19.449
applicants who do end up borrowing from this fund.

00:26:20.059 --> 00:26:24.559
And then details for how borrowers can receive back

00:26:24.568 --> 00:26:27.358
a deposit that they will have to put down as part of

00:26:28.559 --> 00:26:31.959
an award of a loan through this program. The deposit

00:26:31.969 --> 00:26:36.269
is equal to 3% of the total cost, total estimated cost

00:26:36.279 --> 00:26:38.449
of the new plan or upgraded plan.

00:26:40.078 --> 00:26:44.259
The same, the same questions are part of this proposal

00:26:44.269 --> 00:26:49.229
for publication that are for commenters as in the completion

00:26:49.239 --> 00:26:52.390
bonus grant. So we have asked the same sorts of questions

00:26:52.400 --> 00:26:55.358
to our for this program as the questions, the directed

00:26:55.368 --> 00:26:58.449
questions for commenters in the completion bonus grant

00:26:58.459 --> 00:27:01.180
program. Staff recommends that the Commission approve

00:27:01.189 --> 00:27:03.410
this proposal and I'm happy to answer any questions.

00:27:05.390 --> 00:27:05.410
(item:27:Commissioner Glotfelty on small modular rectors) I

00:27:07.098 --> 00:27:09.328
don't have a question. I just have a statement that

00:27:09.420 --> 00:27:12.098
as the guy who's kind of leading the effort on small

00:27:12.130 --> 00:27:15.380
modular reactors in this state. It's my hope that at

00:27:15.390 --> 00:27:17.598
some point in time when they become viable. This program

00:27:17.608 --> 00:27:19.618
is still around and will be able to participate in

00:27:19.630 --> 00:27:23.160
that program. We know that the date, the timelines

00:27:23.170 --> 00:27:26.250
don't match up because this is for dispatchable energy

00:27:26.259 --> 00:27:28.868
now. But if it continues in the future and rolls over

00:27:29.108 --> 00:27:31.390
if the Legislature deems that. Then we'd love for it

00:27:31.400 --> 00:27:35.410
to be available to small modular nuclear reactors.

00:27:36.630 --> 00:27:41.449
Good work. Thank you. Thank you for your work. Thanks. (item:27:Motion to approve PFP) I would

00:27:41.459 --> 00:27:44.049
entertain a motion to approve the proposal for publication.

00:27:44.719 --> 00:27:48.759
So moved. Do I have a second? Second. A motion and a

00:27:48.769 --> 00:27:53.140
second. All in favor, say aye. Aye. Motion passes. (item:28:Chairwoman Jackson lays out Project No. 55566) Next up

00:27:53.150 --> 00:27:57.348
is Item No. 28, Project No. 55566. This is the

00:27:57.358 --> 00:27:59.769
Commission's project for the generation interconnection

00:27:59.779 --> 00:28:02.150
allowance. Shelah, do we have anyone from the public

00:28:02.160 --> 00:28:06.108
signed up to speak on Item No. 28? No, ma'am. PUC

00:28:06.118 --> 00:28:09.439
Staff filed a recommended proposal for publication

00:28:09.729 --> 00:28:12.630
and is here to provide an overview. Could you please

00:28:12.640 --> 00:28:15.789
state your name for the record? (item:28:PUC Staff's Mariah Benson on PFP for implementation of HB1500, Section 9) Hello, Mariah Benson

00:28:15.799 --> 00:28:18.848
Commission Staff. Before you, we have Staff's recommended

00:28:18.858 --> 00:28:22.809
proposal for publication which implements HB1500, Section

00:28:22.818 --> 00:28:26.608
9. Which requires the Commission develop a transmission

00:28:26.618 --> 00:28:29.900
level generation interconnection allowance. Through

00:28:29.910 --> 00:28:32.674
that rulemaking we recommending a two tier allowance

00:28:32.684 --> 00:28:36.045
based on high transmission voltage and low transmission

00:28:36.055 --> 00:28:39.473
voltage. And then we recommend an adjustment need be

00:28:39.483 --> 00:28:44.094
done yearly to account for inflation and other potential

00:28:44.104 --> 00:28:46.324
changes, other things that would potentially change

00:28:46.334 --> 00:28:49.193
the allowance. I'd like to recognize the project

00:28:49.203 --> 00:28:52.144
team on this one. We have Eduardo Acosta, Chris Roelse, 

00:28:52.505 --> 00:28:56.384
John Poole, Tyler Nicholson of course Mackenzie Arthur

00:28:56.394 --> 00:28:59.634
again. And if you guys have any questions, we're

00:28:59.644 --> 00:29:00.713
here and happy to answer them.

00:29:03.519 --> 00:29:07.380
Any thoughts on this one? I do. (item:28:Commissioner Glotfelty's thoughts on PFP) I think you all have

00:29:07.390 --> 00:29:11.608
done a great job on this. Yeah it's a, it's a unique

00:29:11.618 --> 00:29:16.670
policy that is a change from what's happened since

00:29:16.818 --> 00:29:19.630
the late 90's. When we restructured the market

00:29:19.868 --> 00:29:25.289
that was the intent of it. But I think that this the

00:29:25.299 --> 00:29:28.289
way that you all have defined this works for all different

00:29:28.299 --> 00:29:33.400
types of resources equally and nondiscriminating initially

00:29:33.410 --> 00:29:35.049
when I read this and I've had a lot of discussions

00:29:35.059 --> 00:29:39.088
with staff on this and they've been great bringing

00:29:39.098 --> 00:29:41.140
me along and trying to understand it. But these are

00:29:41.150 --> 00:29:44.769
not t cost dollars for moving the power beyond the

00:29:44.779 --> 00:29:47.009
interconnection. These are just interconnection costs

00:29:47.019 --> 00:29:49.630
So we have to keep that in mind that this is that

00:29:49.640 --> 00:29:53.049
it's a small portion of, of what that, what that means

00:29:53.059 --> 00:29:57.309
for a facility, it may impact some renewables more

00:29:58.269 --> 00:30:01.469
But what what this does is, in my opinion, it will

00:30:01.479 --> 00:30:06.098
force some financial discipline on citing for renewables

00:30:06.108 --> 00:30:11.049
and other facilities. If it moves them closer to interconnecting

00:30:11.059 --> 00:30:14.949
facilities, then they're, they're going to be ok. These

00:30:14.959 --> 00:30:18.358
numbers will allow them to interconnect. If they move

00:30:18.368 --> 00:30:21.930
far away, per their decision, they may have to pay

00:30:21.939 --> 00:30:26.588
more, but it's all laid out and these rules if passed

00:30:26.680 --> 00:30:29.250
And when we get comments back, if we finally pass a

00:30:29.259 --> 00:30:33.750
rule like this, it it won't be, it will be very clear

00:30:33.759 --> 00:30:36.239
as to what the price would be that they would have

00:30:36.250 --> 00:30:41.759
to pay. So while a, a generator might choose to exceed

00:30:41.838 --> 00:30:45.118
the allowance, they will know ahead of time how much

00:30:45.130 --> 00:30:47.029
they will be exceeding the allowance and can budget

00:30:47.039 --> 00:30:51.739
for that in their in their development costs. And finally

00:30:51.750 --> 00:30:55.509
the one thing I would say is I'm interested in hearing

00:30:55.519 --> 00:30:57.588
from stakeholders on one part of this and that's the

00:30:57.598 --> 00:30:58.729
section on

00:31:00.739 --> 00:31:03.868
upgrades to existing facilities. We have a lot of wind

00:31:03.880 --> 00:31:08.338
facilities, we have potentially plants that are upgrading

00:31:08.660 --> 00:31:11.920
are switching from coal to gas. You know, other types

00:31:11.930 --> 00:31:14.959
of resources that may be switching at a single location

00:31:14.969 --> 00:31:17.439
And the question becomes, are those interconnection

00:31:17.449 --> 00:31:21.299
costs enough or right now they're not included. They

00:31:21.309 --> 00:31:23.939
wouldn't get any upgrade costs after 10 years. If I'm

00:31:23.949 --> 00:31:28.150
correct on that? They wouldn't get any interconnected

00:31:28.439 --> 00:31:30.170
interconnection upgrade costs.

00:31:32.019 --> 00:31:34.549
(item:28:Mariah Benson on interconnection allowance) Any costs that are not transmission system upgrade

00:31:34.559 --> 00:31:37.939
costs that would benefit the entire grid. After 10

00:31:37.949 --> 00:31:40.328
years, they would be eligible for another allowance. Oh, they

00:31:40.618 --> 00:31:43.750
would be. In 10 years they need, they only have the

00:31:43.759 --> 00:31:45.689
rest of the allowance that they originally used to

00:31:45.699 --> 00:31:48.608
interconnect. Okay. Thank you for that clarification

00:31:48.618 --> 00:31:50.828
and I will withdraw my comment. But I look forward

00:31:50.838 --> 00:31:51.608
to all the comments.

00:31:53.848 --> 00:31:56.410
Thanks. (item:28:Commissioner Cobos' thoughts on PFP) Thank you for your work on this that this is a great

00:31:56.420 --> 00:31:59.670
work on implementing this Legislation. And Commissioner

00:32:00.068 --> 00:32:03.750
Glotfelty mentioned, you know, I think um creates certainty

00:32:03.759 --> 00:32:08.519
for um citing and um investment decisions and um look

00:32:08.529 --> 00:32:12.289
forward to hearing the uh stakeholder comments on on

00:32:12.299 --> 00:32:18.019
this uh PFP or, and um thank you for your work.

00:32:20.500 --> 00:32:22.660
(item:28:Motion to approve PFP) I would entertain a motion to approve the proposal

00:32:22.670 --> 00:32:26.900
for publication. So moved. Second. A motion and a second. All

00:32:26.910 --> 00:32:30.930
in favor, say aye. Aye. Motion passes. And I'm so sorry, I forgot to

00:32:30.939 --> 00:32:33.259
mention as well. From rates, we also had Bill Abbott

00:32:33.269 --> 00:32:34.509
on this rulemaking.

00:32:36.088 --> 00:32:41.009
Well done Mariah. Thank you, Bill. Thank you. (item:29:Chairwoman Jackson lays out Project No. 54585) Next up

00:32:41.019 --> 00:32:45.269
is Item No. 29, Project No 54585. This is the

00:32:45.279 --> 00:32:48.219
Commission's project for the emergency pricing program.

00:32:48.549 --> 00:32:50.509
Shelah, do we have anyone from the public signed up to

00:32:50.519 --> 00:32:55.259
speak on Item No 29? No, ma'am. PUC Staff filed

00:32:55.269 --> 00:32:58.689
a recommended order for adoption and is here to provide

00:32:58.699 --> 00:33:01.828
a brief overview. Could you please state your name

00:33:01.838 --> 00:33:04.868
for the record? (item:29:PUC Staff's David Smeltzer on Emergency Pricing Program) Yes, David Smeltzer Commission, Commission

00:33:04.880 --> 00:33:07.150
Staff. And up here with me are Julie Blocker and Werner

00:33:07.279 --> 00:33:09.689
Roth. And because this is the more efficient way to do

00:33:09.699 --> 00:33:12.219
it. Maybe I'll just note that Mac didn't work on this

00:33:12.229 --> 00:33:15.939
project. That's just, that's the more orderly way to

00:33:15.949 --> 00:33:18.650
go. So we had a good uh discussion on this at the

00:33:18.660 --> 00:33:21.259
last open meeting. As we know, this is our SB3

00:33:22.000 --> 00:33:23.818
implement, like we're implementing a portion of SB3

00:33:23.828 --> 00:33:25.689
from last Session. That requires an Emergency

00:33:25.699 --> 00:33:28.890
Pricing Program for when prices have been at the H

00:33:28.900 --> 00:33:32.858
cap in any 12 hours in a 24 hour period. Um 

00:33:32.868 --> 00:33:36.529
last open meeting. I think we had a good discussion

00:33:36.539 --> 00:33:40.219
about whether or not the recovery of costs that generator

00:33:40.229 --> 00:33:43.209
should be allowed to um you know, they should be able

00:33:43.219 --> 00:33:46.229
to recover these costs above the emergency cap and

00:33:46.239 --> 00:33:49.500
whether or not, that should be capped at what the cap

00:33:49.509 --> 00:33:52.009
would have been had that moved on. And so based on

00:33:52.019 --> 00:33:54.699
advice from you guys, the guidance that we received

00:33:54.709 --> 00:33:57.949
at the last open meeting. Staff has made a number of

00:33:57.959 --> 00:34:01.818
changes to the rule upon final adoption. The first

00:34:01.828 --> 00:34:04.828
thing that we did is we defined emergency conditions

00:34:05.118 --> 00:34:09.539
which are one of the the termination triggers for leaving

00:34:09.550 --> 00:34:12.079
emergency pricing program and where Staff is recommending

00:34:12.199 --> 00:34:15.708
a definition of anything anytime we're an EEA because

00:34:15.719 --> 00:34:18.648
if we're still in EEA, then the system has not returned

00:34:18.659 --> 00:34:21.478
to all, you know, it's not conditions normal. And so

00:34:21.489 --> 00:34:24.789
the, the e cap should remain in effect for pricing purposes

00:34:24.800 --> 00:34:28.179
until 24 hours after that time to best preserve and

00:34:28.188 --> 00:34:32.867
protect the day head market. Um We've also um included

00:34:32.878 --> 00:34:36.268
some additional language around the verifiable cost

00:34:36.278 --> 00:34:39.768
mechanism and so if they want to require, require costs

00:34:39.778 --> 00:34:43.028
above, um what would you know what H cap would have

00:34:43.039 --> 00:34:45.489
been if H cap were still in effect? Uh We're gonna

00:34:45.498 --> 00:34:48.798
require an additional attestation that any uh fuel

00:34:48.849 --> 00:34:51.728
related cost recovery was in fact related to fuel or

00:34:51.739 --> 00:34:54.887
services directly associated with that, that fuel recovery

00:34:55.137 --> 00:34:58.798
And we've given ERCOT the ability to or we've clarified

00:34:58.867 --> 00:35:01.259
an ability that we think they already have, which is

00:35:01.268 --> 00:35:04.168
to request uh whatever documents they need to verify

00:35:04.177 --> 00:35:08.188
those costs uh including a fuel contracts. Other

00:35:08.197 --> 00:35:11.528
changes that were made after, since adoption the most

00:35:11.539 --> 00:35:15.079
significant are we added a new Paragraph 7 which

00:35:15.088 --> 00:35:19.070
basically provides some holding text for uh to make

00:35:19.079 --> 00:35:20.949
sure that ERCOT has all the authority they need to

00:35:20.958 --> 00:35:24.079
implement that this winter even if they can't get their

00:35:24.090 --> 00:35:27.878
protocols um approved by us in time. And so it just

00:35:27.889 --> 00:35:30.898
sets out some uh temporary provisions. Um and, and

00:35:30.909 --> 00:35:32.429
now that I think about it, the one other change that

00:35:32.438 --> 00:35:38.550
we made uh is that we, we clarified that the costs

00:35:38.699 --> 00:35:42.239
that are recovered will be allocated on a load ratio

00:35:42.250 --> 00:35:45.590
share basis so that it's, it's, it's even across the

00:35:45.599 --> 00:35:50.628
board and everyone shares the burden, which is a slight

00:35:50.639 --> 00:35:52.489
deviation from the way that cost recovery works in

00:35:52.500 --> 00:35:56.369
other contexts where they use capacity short method

00:35:56.378 --> 00:35:58.728
because often individual entities are responsible for

00:35:58.739 --> 00:36:01.688
those shorts. So I mean, that is consistent with stakeholder

00:36:01.699 --> 00:36:05.849
recommendations. I'm the team and I are happy to answer

00:36:05.860 --> 00:36:08.148
any additional questions that you may have. And also

00:36:08.159 --> 00:36:12.090
I believe that Commissioner Cobos filed a memo on this

00:36:12.099 --> 00:36:14.409
as well. Thank you, David.

00:36:16.610 --> 00:36:20.050
(item:29:Commissioner Cobos lays out her memo) Some of the changes made to the uh proposal for adoption

00:36:20.059 --> 00:36:24.148
I think um are are good changes that provide additional

00:36:24.159 --> 00:36:28.688
safeguards um during the EPP periods, I think number

00:36:28.699 --> 00:36:33.030
one changing it from 72 hours to 24 hours uh A period

00:36:33.059 --> 00:36:37.010
that uh EPP is in effect um the emphasis on the recovery

00:36:37.019 --> 00:36:40.829
of marginal costs, the process you laid out for um

00:36:40.840 --> 00:36:45.800
costs above an h cap with respect to requiring the

00:36:46.309 --> 00:36:49.708
resource entities to provide an attestation and any

00:36:49.719 --> 00:36:52.780
information that ERCOT requests to evaluate their costs

00:36:52.789 --> 00:36:55.010
to determine whether they're reasonable, verifiable

00:36:55.019 --> 00:36:58.840
costs. And so I, I think that the process you've laid

00:36:58.849 --> 00:37:00.860
out and the additional safeguards you've put into the

00:37:00.869 --> 00:37:04.139
role um have put me in a more comfortable position

00:37:04.360 --> 00:37:08.668
with the proposal. My memos just intended to reinforce

00:37:08.679 --> 00:37:12.329
and emphasize that um ERCOT must get the attestation

00:37:12.340 --> 00:37:15.789
and any information they need to evaluate the reasonableness

00:37:15.800 --> 00:37:19.708
of the, to verify those costs. And that's something

00:37:19.719 --> 00:37:22.250
ERCOT is gonna do anyway, but I wanted to get it in

00:37:22.260 --> 00:37:24.519
in the rule just to make it clear that we expect that

00:37:24.530 --> 00:37:27.800
the resource entities um, would provide this information

00:37:27.809 --> 00:37:31.110
to ERCOT and if they don't, then, um, ERCOT wouldn't

00:37:31.119 --> 00:37:34.599
approve the recovery of those costs. Excellent. I think

00:37:34.610 --> 00:37:37.239
Commission Staff is supportive of the change that you

00:37:37.250 --> 00:37:41.148
recommend. We would. If you, if you're not opposed

00:37:41.159 --> 00:37:45.429
to it. We might request a little discretion to tweak

00:37:45.438 --> 00:37:47.739
it and put it into the rule according to normal drafting

00:37:47.750 --> 00:37:52.250
conventions and uh, maybe put it at the, uh, at the

00:37:52.260 --> 00:37:54.409
subparagraph level instead of just 1, 2, 3. But I mean,

00:37:54.418 --> 00:37:57.039
the substance exactly what you spelled out is perfect

00:37:57.050 --> 00:37:59.590
for us. Whatever makes sense from your rulewriting

00:37:59.599 --> 00:38:01.289
perspective. But thank you so much. Thank you

00:38:03.059 --> 00:38:05.510
(item:29:Commissioner McAdams on memo and EPP) Madam Chair, I agree with the change. I appreciate

00:38:05.519 --> 00:38:08.840
Commissioner Cobos following it up. It, it puts iron

00:38:09.449 --> 00:38:12.739
in the glove of ERCOT to, to gather this information

00:38:13.340 --> 00:38:16.628
It, it reassures the system that somebody is going

00:38:16.639 --> 00:38:21.539
to be checking to see what exactly is going on in the

00:38:21.550 --> 00:38:24.938
event of an emergency. And it's just one more measure

00:38:24.949 --> 00:38:29.570
that allows us to gauge the overall impact to the system

00:38:29.840 --> 00:38:33.659
and, and root causes potentially as well. So I applaud

00:38:33.668 --> 00:38:36.469
Staff in the way that they've attempted to thread the

00:38:36.478 --> 00:38:38.829
needle on this and appreciate the efforts.

00:38:41.820 --> 00:38:45.728
(item:29:Chairwoman Jackson on EPP and memo) I agree with the um, with the rule as adopted with

00:38:45.739 --> 00:38:48.599
the change from Commissioner Cobos. And um, really

00:38:48.610 --> 00:38:50.800
appreciate her taking a look at it and drilling down

00:38:50.809 --> 00:38:52.978
and also all the work that Staff did on this one. I

00:38:52.989 --> 00:38:56.809
think this is a great, a great outcome and something

00:38:56.820 --> 00:38:59.360
that was very much needed and really pleased that we're

00:38:59.369 --> 00:39:03.289
moving forward with this at that time. So um, I would

00:39:03.969 --> 00:39:05.809
unless you would like to make the motion, Commissioner

00:39:06.250 --> 00:39:09.208
Cobos? That's fine with me. (item:29:Motion to approve proposal for adoption) So I would move to adopt Staff's

00:39:09.219 --> 00:39:13.079
proposal for adoption with the addition of the language

00:39:13.090 --> 00:39:13.769
in my memo.

00:39:15.550 --> 00:39:18.139
Second. I have a motion and a second. All in favor, say aye. 

00:39:18.148 --> 00:39:19.079
Aye. Motion passes.

00:39:21.070 --> 00:39:24.050
I don't have anything for Item No. 30. (item:31:Chairwoman Jackson lays out Project No. 55323) Next up is

00:39:24.059 --> 00:39:29.010
Item No. 31, Project No. 55323. This is the Commission's

00:39:29.019 --> 00:39:32.369
rule making related to its goal for renewable energy

00:39:32.800 --> 00:39:38.769
and proposed new Section 25.173 relating to the renewable

00:39:38.780 --> 00:39:41.898
energy credit. Shelah do we have anyone from the public

00:39:41.909 --> 00:39:45.579
signed up to speak on Item No. 31? No, ma'am. PUC

00:39:45.719 --> 00:39:49.309
Staff filed a recommended order for adoption and is

00:39:49.320 --> 00:39:52.418
here to provide a brief overview. Could you please

00:39:52.429 --> 00:39:55.599
state your name for the record? Yes, ma'am. (item:31:PUC Staff's Zachary Dollar on Renewable Standard Portfolio) Good morning,

00:39:55.610 --> 00:39:58.699
Commissioners. Zachary Dollar for Commission Staff. House

00:39:58.708 --> 00:40:01.398
Bill 1500 from the 88th Legislative Session repealed

00:40:01.409 --> 00:40:03.949
the renewable energy credits trading program under

00:40:03.958 --> 00:40:06.688
Section 39.904 of the Public Utility Regulatory

00:40:06.699 --> 00:40:09.369
Act. But required the Commission to continue the trading

00:40:09.378 --> 00:40:11.949
program and mandatory renewable portfolio standard

00:40:11.958 --> 00:40:14.530
for only solar generation until the program's complete

00:40:14.539 --> 00:40:18.639
repeal effective September 1, 2025. House Bill 1500 also

00:40:18.648 --> 00:40:21.619
required ERCOT to continue to maintain the accreditation

00:40:21.628 --> 00:40:24.309
and banking system to award and track all renewable

00:40:24.320 --> 00:40:28.010
energy credits on a voluntary basis. In response to

00:40:28.019 --> 00:40:30.320
feedback from ERCOT and stakeholders Commission Staff

00:40:30.329 --> 00:40:32.840
has modified the proposed rule language to do the following.

00:40:33.769 --> 00:40:36.659
One, clarify that ERCOT will continue to use the existing

00:40:36.668 --> 00:40:39.438
trading program framework to administer the mandatory

00:40:39.449 --> 00:40:42.820
solo RPS and manage the voluntary accreditation and

00:40:42.829 --> 00:40:46.719
banking of all recs. Two, add language to state that market

00:40:46.728 --> 00:40:49.269
participants previously registered or certified to

00:40:49.280 --> 00:40:52.398
participate in the rec trading program under repealed

00:40:52.409 --> 00:40:56.179
Section 25.173 continue to be registered and certified

00:40:56.188 --> 00:40:58.739
for participation in the rec trading program, program 

00:40:58.750 --> 00:41:03.708
under new section 25.173. Additionally, Commission

00:41:03.719 --> 00:41:05.840
Staff is recommending two changes to the file draft

00:41:05.849 --> 00:41:08.489
to correct non substantive editorial errors identified

00:41:08.500 --> 00:41:11.340
after the filing. Commission Staff recommends that the

00:41:11.349 --> 00:41:13.500
Commission approve the order for adoption as Staff

00:41:13.510 --> 00:41:15.898
recommends in the Texas Register. Thank you. And I'm

00:41:15.909 --> 00:41:17.099
happy to answer any questions.

00:41:19.639 --> 00:41:20.458
Good job.

00:41:23.139 --> 00:41:25.559
I think this is the first time presenting before the

00:41:25.570 --> 00:41:27.929
Commission, so you did a great job. Thank you. So I appreciate

00:41:27.938 --> 00:41:28.739
all the hard work.

00:41:30.579 --> 00:41:33.570
Thank you both. Appreciate it. Thank you. Good job. (item:31:Motion to approve Staff's recommendation for adoption) I would entertain a motion to

00:41:33.579 --> 00:41:36.869
approve Staff's recommendation for adoption. So moved.

00:41:38.010 --> 00:41:41.550
Second. I have a motion and a second. All in favor, say aye.

00:41:41.559 --> 00:41:46.289
Aye. Motion passes. (item:32:Chairwoman Jackson lays out Project No. 41155) Next up is Item No. 32, Project

00:41:46.300 --> 00:41:50.070
No. 41155. This is the Commission's project for

00:41:50.079 --> 00:41:53.530
proposed revisions or additions to ERCOT's transmission

00:41:53.539 --> 00:41:57.228
planning guidelines and procedures. ERCOT requested

00:41:57.239 --> 00:42:00.389
the Commission provide input regarding the policy impact

00:42:00.398 --> 00:42:03.750
of PGRR105. Shelah, do we have anyone from the public

00:42:03.760 --> 00:42:08.469
signed up to speak on Item No. 32? No, ma'am. PUC Staff

00:42:08.478 --> 00:42:11.550
filed a memo and is here to lay out their recommendation.

00:42:12.039 --> 00:42:14.769
Could you please state your name for the record? (item:32:PUC Staff's Floyd Walker on gaining Commission input) Floyd

00:42:14.780 --> 00:42:17.869
Walker, Commission Staff. I'm here with Ramya Ramaswamy.

00:42:19.039 --> 00:42:22.679
On September 22, ERCOT filed a request pursuant to

00:42:22.688 --> 00:42:27.969
16 TAC 25.361(d)(3). To get a Commission input

00:42:28.050 --> 00:42:31.800
regarding planning issues and simply relating to PGRR105

00:42:31.958 --> 00:42:37.619
which would change some planning transmission policies.

00:42:37.628 --> 00:42:43.750
So, um and the Commission has now filed a memo to provide

00:42:43.760 --> 00:42:47.208
suggested input that the Commission could provide to

00:42:47.219 --> 00:42:49.969
ERCOT in response to it's request. And Ramya will lay

00:42:49.978 --> 00:42:53.030
out some of the details. (item:31:PUC Staff's Ramya Ramaswamy lays out policy considerations) Good morning Chair. Good morning, 

00:42:53.039 --> 00:42:57.188
Commissioners. Ramya Ramaswamy for Commission Staff. I

00:42:57.199 --> 00:42:59.898
just want to remind everyone once again, PGRR105

00:42:59.909 --> 00:43:03.449
is not in front of us today. We are here just to

00:43:03.458 --> 00:43:08.050
talk about some of the policy considerations that Staff

00:43:08.059 --> 00:43:13.309
has identified um that should be addressed. Also

00:43:13.320 --> 00:43:17.849
because ERCOT has requested input from the Commission.

00:43:18.289 --> 00:43:21.349
Staff has identified three different concerns that

00:43:21.360 --> 00:43:24.590
we have as laid out in our memo. We have concerns with

00:43:24.599 --> 00:43:28.250
reversing directive six. We have and that also leads

00:43:28.260 --> 00:43:32.489
has um significant co that could have significant cost

00:43:32.500 --> 00:43:36.869
implications in the long run and might have certain

00:43:36.878 --> 00:43:42.530
um lack of control issues depending on how the policy

00:43:42.539 --> 00:43:45.300
moves forward. We would love to get input from the

00:43:45.309 --> 00:43:47.860
Commission and we are here to answer any questions.

00:43:47.869 --> 00:43:52.219
Thank you. (item:32:Commissioner Cobos lays out her thoughts) So I, I'm happy to kind of lay out sort

00:43:52.228 --> 00:43:54.699
of the, this is the way I'm looking at the issue. So

00:43:55.300 --> 00:43:55.800
um

00:43:57.438 --> 00:43:59.500
you know, pursuant to Legislation that Commissioner

00:43:59.510 --> 00:44:01.909
McAdams was involved in. Apparently that requires D.C.

00:44:01.918 --> 00:44:06.340
ties to get a CCN from the Commission. Southern Cross

00:44:06.369 --> 00:44:10.188
came to the Commission and filed a CCN application that

00:44:10.199 --> 00:44:15.389
was approved in May of 2017. And that, that same and

00:44:15.398 --> 00:44:19.030
on that same day May 23, 2017. The Commission issued

00:44:20.449 --> 00:44:24.059
a revised order creating and scoping project which

00:44:24.070 --> 00:44:27.590
essentially laid out 14 directives for ERCOT to go

00:44:27.599 --> 00:44:32.628
look at. And as part of those directives, Directive

00:44:32.639 --> 00:44:36.739
No. 6 is one of the applicable directives that

00:44:37.228 --> 00:44:40.239
touches on the figure that's before us. But essentially

00:44:40.250 --> 00:44:42.639
directive number six states that ERCOT shall study

00:44:42.648 --> 00:44:45.099
and determine what transmission upgrades if any are

00:44:45.110 --> 00:44:48.679
necessary to manage congestion resulting from power

00:44:48.688 --> 00:44:51.378
flows over the Southern Cross tie, make any necessary

00:44:51.389 --> 00:44:54.550
visions to its standards, guides systems and protocols

00:44:54.559 --> 00:44:56.659
as appropriate. And certified the Commission when it

00:44:56.668 --> 00:45:00.539
has completed this action, these actions. So ERCOT

00:45:00.550 --> 00:45:04.458
essentially determined that they would zero out the

00:45:04.469 --> 00:45:08.099
D.C. ties in their transmission reliability criteria.

00:45:08.110 --> 00:45:11.128
You know, there were concerns about the dependability

00:45:11.139 --> 00:45:13.349
of the resources on the other side of the fence and

00:45:13.360 --> 00:45:17.619
other markets and in countries, I guess. Determined

00:45:17.628 --> 00:45:21.898
that um they wouldn't be included in the transmission

00:45:21.909 --> 00:45:27.418
reliability criteria and pass payer 77 to affect um

00:45:27.429 --> 00:45:32.340
that, that position. And so um Directive No. 11

00:45:32.349 --> 00:45:35.619
which touches on the cost allocation for those transmission

00:45:35.628 --> 00:45:38.699
upgrades was not addressed because um there was nothing

00:45:38.708 --> 00:45:42.500
to allocate because they decided to um zero out the

00:45:43.418 --> 00:45:48.269
the D.C. ties into transmission analysis. So ultimately

00:45:48.280 --> 00:45:50.179
you know, ERCOT reported this in, in some updates to

00:45:50.188 --> 00:45:55.369
the Commission. And um in September of 2022, the Commission

00:45:55.378 --> 00:45:59.750
um basically closed out the scoping project uh project

00:45:59.760 --> 00:46:05.929
number 463 um 04. stating that they believe Derco had

00:46:05.938 --> 00:46:10.159
completed um all the work on the directives. And then

00:46:10.168 --> 00:46:15.898
um the following year in I believe, April of '23. Rainbow

00:46:15.909 --> 00:46:16.958
filed PGRR105

00:46:18.570 --> 00:46:24.269
which essentially says that it makes some changes

00:46:24.280 --> 00:46:27.369
to the planning guides to ensure full deliverability

00:46:27.378 --> 00:46:31.458
of the DC ties. So essentially the Southern Cross precedent

00:46:31.469 --> 00:46:36.289
is zero and the PGRR105 is 100%. So we're like in

00:46:36.300 --> 00:46:43.260
between 0 and 100%. And so, um you know, the figure

00:46:43.269 --> 00:46:46.519
would essentially reverse course on prior precedent

00:46:47.228 --> 00:46:51.679
and um does raise some policy considerations that are

00:46:51.688 --> 00:46:55.639
appropriate for the Commission to address from my perspective.

00:46:56.269 --> 00:46:58.780
But I think that first and foremost, we got to decide

00:46:58.789 --> 00:47:02.500
um from our perspective, whether, you know, is, is

00:47:02.510 --> 00:47:05.800
zero, what we want to stick to based on the prior Southern

00:47:05.809 --> 00:47:09.719
Cross precedent. Are we comfortable with 100% recognizing

00:47:09.728 --> 00:47:13.438
that, you know, in my conversations with ERCOT and

00:47:13.449 --> 00:47:17.398
technical experts, you know, there are some the practical

00:47:17.409 --> 00:47:20.280
realities of some of our existing ties, like for instance

00:47:20.289 --> 00:47:22.989
the ties into Mexico. You know, Mexico will tell us

00:47:23.000 --> 00:47:25.619
on a daily basis. You know, will tell ERCOT on a daily

00:47:25.628 --> 00:47:28.309
basis. That you know how many megawatts they can actually

00:47:28.320 --> 00:47:32.550
provide. And um ERCOT will look and say, well, this

00:47:32.559 --> 00:47:34.469
is how much we can accommodate on our side of the fence

00:47:34.478 --> 00:47:37.059
based on the transmission that exists on our side um

00:47:37.070 --> 00:47:40.559
in ERCOT and so not in every circumstance where you

00:47:40.570 --> 00:47:43.500
get the full deliverability of that tie and practical

00:47:43.510 --> 00:47:46.168
reality and that's on existing ties and then you have

00:47:46.179 --> 00:47:49.059
the new ties where, you know, we, we just don't know

00:47:49.070 --> 00:47:51.869
we, we have, you know, we, we'd like to get all of

00:47:51.878 --> 00:47:54.579
the power that the tie can bring over, but we don't

00:47:54.590 --> 00:48:00.239
know for certain. Um And so do we want to build a

00:48:00.250 --> 00:48:03.610
transmission system on our side in ERCOT to accommodate

00:48:03.619 --> 00:48:08.449
full deliverability? Um given some of the unknown factors

00:48:08.458 --> 00:48:11.300
and uncertainties and then ultimately, how would we

00:48:11.309 --> 00:48:15.349
cost allocate those transmission upgrades. You know

00:48:15.360 --> 00:48:17.909
there's stakeholders, I think wanna allocate it to

00:48:18.139 --> 00:48:21.628
to the D.C. tie. I because there would be generation resources

00:48:21.639 --> 00:48:24.500
And then, you know, there's a perspective of these

00:48:24.510 --> 00:48:27.699
the flows coming in the imports provide a public good

00:48:27.708 --> 00:48:29.938
for the, the whole system. So they should be allocated

00:48:29.949 --> 00:48:35.760
on t cost basis. You know I, I have some concerns

00:48:35.769 --> 00:48:40.708
with 100% deliverability um given the uncertainties

00:48:40.719 --> 00:48:44.099
um that could exist um in other countries and other

00:48:44.110 --> 00:48:49.090
neighboring RTOs in building a system to accommodate

00:48:49.099 --> 00:48:53.050
100% deliverability, given those uncertainties and                                                                                                            

00:48:53.119 --> 00:48:59.519
um unknown factors. However I, I think that it would                                                                                                                                                                                       

00:48:59.530 --> 00:49:03.099
be helpful to examine whether there's some middle ground

00:49:03.110 --> 00:49:06.409
If the Commission wishes to look at, how do we potentially

00:49:06.418 --> 00:49:10.199
optimize more imports through D.C. ties? Maybe it's not

00:49:10.228 --> 00:49:14.320
100% deliverability but, but doing some kind of analysis

00:49:14.688 --> 00:49:16.989
of determining on average how much you're getting over

00:49:17.000 --> 00:49:19.840
the existing ties and coming up with some middle ground

00:49:20.250 --> 00:49:25.219
to potentially optimize more DC T imports into ERCOT

00:49:25.530 --> 00:49:29.820
So, um I'm not comfortable with 100% deliverability

00:49:29.829 --> 00:49:35.458
under the PGRR105. But I'm open to examining is, is

00:49:35.469 --> 00:49:39.958
there, is there somewhere in between zero and 100 that

00:49:39.969 --> 00:49:43.478
we can look at and, and getting feedback from ERCOT

00:49:43.489 --> 00:49:45.989
of what, what are some options of, of how we can find

00:49:46.000 --> 00:49:48.119
a middle ground and from the stakeholder community

00:49:48.409 --> 00:49:51.179
on not only how we can determine a mi middle ground

00:49:51.188 --> 00:49:55.070
but also a process for doing that. Um because I'm not

00:49:55.079 --> 00:49:57.909
sure that the, the answer is, I mean, I'm not comfortable

00:49:57.918 --> 00:50:01.500
with 100% and I'm not sure zero is the complete answer

00:50:01.860 --> 00:50:04.659
given some of the um you know, some of the events we've

00:50:04.668 --> 00:50:08.340
had, right? And, and um should we try to optimize these

00:50:08.349 --> 00:50:12.260
ties? And if so, what is the appropriate middle ground

00:50:12.530 --> 00:50:16.340
And how do we get there? And perhaps we can, you know

00:50:16.349 --> 00:50:20.019
query ERCOT stakeholders um get some comments.

00:50:20.030 --> 00:50:23.898
I'd be happy to develop some questions to, to get me

00:50:23.909 --> 00:50:26.070
make sure we get the right information to help us move

00:50:26.079 --> 00:50:28.199
forward and then we can determine how we do that if

00:50:28.208 --> 00:50:31.570
we decide to move forward. But I, I'm not comfortable

00:50:31.579 --> 00:50:33.809
with PGRR105 at this stage.

00:50:37.019 --> 00:50:40.619
Thanks, Commissioner. Appreciate it. (item:32:Commissioner Glotfelty's thoughts on ERCOT guidance) First of all,

00:50:40.628 --> 00:50:42.619
I think the question on the table is, should we give

00:50:42.918 --> 00:50:45.840
ERCOT guidance? That's really the only question on

00:50:45.849 --> 00:50:50.360
the table. And I would say that when they came and

00:50:50.369 --> 00:50:55.969
released the RFP for capacity, we over here, I will

00:50:55.978 --> 00:50:58.340
speak for myself. But I think that it was unanimous

00:50:58.349 --> 00:51:02.128
that we raised cane because they didn't come talk to

00:51:02.139 --> 00:51:05.000
us ahead of time and ask our opinion and let us give

00:51:05.010 --> 00:51:09.628
them advice and thoughts on that. And then when we

00:51:09.760 --> 00:51:13.989
get asked to do that, if we say no, we're not willing

00:51:14.000 --> 00:51:18.889
to give you our views, we're sending mixed signals

00:51:18.898 --> 00:51:23.769
So we have to make sure that we are, I think consistent

00:51:23.780 --> 00:51:27.019
in this space. And to me that would mean we give them

00:51:27.030 --> 00:51:29.849
direction, that PGRR105 is the right route that

00:51:29.860 --> 00:51:34.208
we, we ought to go. I'm the one who made the mistake

00:51:34.219 --> 00:51:36.929
when we closed out the directives on the Southern Cross

00:51:36.938 --> 00:51:40.449
Project. We, I thought that all of the issues were

00:51:40.458 --> 00:51:43.119
resolved. And in fact, this is the one that was not

00:51:43.128 --> 00:51:47.280
resolved. And I would have pushed for a discussion

00:51:47.708 --> 00:51:52.659
back in 2022 had I known this was, was still there

00:51:52.668 --> 00:51:57.320
So, so that's my mistake. And I think we got 90% of

00:51:57.329 --> 00:52:01.239
the way there. Our goal for closing out those directives

00:52:01.530 --> 00:52:06.269
was to give certainty, financial and regulatory certainty

00:52:06.280 --> 00:52:10.438
For DC lines, DC lines are very different than AC lines

00:52:10.699 --> 00:52:14.378
You finance a DC line like you do a pipeline, you go

00:52:14.389 --> 00:52:17.148
out and you get capacity contracts and when you get

00:52:17.159 --> 00:52:19.688
enough capacity contracts, you monetize them and get

00:52:19.699 --> 00:52:22.449
enough money to build the project. It's just a different

00:52:22.458 --> 00:52:28.610
kind of an animal than a regular DC line is. So we

00:52:28.619 --> 00:52:34.849
can't treat them exactly like AC lines. To that

00:52:34.860 --> 00:52:40.648
end, I I think the flexibility provided by PGRR105

00:52:41.030 --> 00:52:48.739
it does not eliminate the ability for us to determine

00:52:48.750 --> 00:52:51.168
how much transmission needs to be built and how much

00:52:51.179 --> 00:52:54.059
would go into rates. That is still a decision that

00:52:54.070 --> 00:52:57.168
we get to make in the future. This just says in the

00:52:57.179 --> 00:53:00.559
planning models, they're going to determine that the

00:53:00.570 --> 00:53:03.648
full flow across that line was is going to be considered

00:53:04.340 --> 00:53:07.809
and what upgrades would be necessary to to allow that

00:53:07.820 --> 00:53:08.398
to happen.

00:53:12.869 --> 00:53:16.030
PGRR105 if we pass it, it does not preclude us from

00:53:16.039 --> 00:53:19.059
doing a rulemaking on this in the future to really

00:53:19.070 --> 00:53:25.378
discuss in totality processes, thoughts theories, operations

00:53:25.389 --> 00:53:29.438
of DC lines, both interregional and intra regional

00:53:29.449 --> 00:53:32.969
within ERCOT by itself. There are some, there have

00:53:32.978 --> 00:53:38.445
been at least two intra regional DC lines. One was

00:53:38.454 --> 00:53:41.135
considered during cres, one was considered as a West

00:53:41.144 --> 00:53:46.074
Texas export project into San Antonio. But it's very

00:53:46.083 --> 00:53:48.784
easy to say that these things can't work in ERCOT because

00:53:48.793 --> 00:53:52.228
we don't have anything that really talks about the

00:53:52.239 --> 00:53:57.340
process for developing these lines in our region. So

00:53:57.349 --> 00:54:01.349
I would be in favor of passing 105. And if we want

00:54:01.360 --> 00:54:04.119
to consider a rulemaking, that would be a valuable

00:54:04.128 --> 00:54:09.780
certainty for the industry. One comment that I have

00:54:09.789 --> 00:54:14.719
that I took issue with, with the Staff's memo and I

00:54:14.728 --> 00:54:17.699
put them in touch with one of the HVDC vendors. 

00:54:17.719 --> 00:54:22.418
The new HVDC lines in their converter stations can

00:54:22.918 --> 00:54:23.929
be integrated into SCED.

00:54:26.010 --> 00:54:28.789
And when they do that, they become part of the system

00:54:29.050 --> 00:54:31.019
they would have to bid into the day ahead market, they

00:54:31.030 --> 00:54:33.398
would have to deliver like a generation resource does

00:54:33.409 --> 00:54:37.478
just like any other generator does at a DC converter

00:54:37.489 --> 00:54:40.000
station. When they're interconnected to the ERCOT system

00:54:40.059 --> 00:54:46.829
they look no different than a generator. So Staff has

00:54:47.199 --> 00:54:51.659
lined up a discussion with Siemens who is one of the

00:54:51.668 --> 00:54:55.539
few builders of converter stations for December to

00:54:55.550 --> 00:54:57.978
discuss that issue with them and to better understand

00:54:57.989 --> 00:54:58.579
how

00:55:00.869 --> 00:55:03.639
energy across these lines can be integrated into SCED

00:55:04.260 --> 00:55:07.168
These are for new lines, these aren't for the old lines

00:55:07.179 --> 00:55:09.449
The old lines still have a very different process but

00:55:09.458 --> 00:55:12.320
new lines provide voltage support, can be integrated

00:55:12.329 --> 00:55:15.409
into SCED and can be very, very valuable in terms of

00:55:15.418 --> 00:55:16.688
flexibility for the system.

00:55:19.349 --> 00:55:22.619
The other thing that I had suggested was with discussions

00:55:22.628 --> 00:55:26.099
with ERCOT is if in fact, these upgrades are if, if

00:55:26.110 --> 00:55:31.179
we, if PGRR105 is approved. Which I hope it is. That

00:55:31.188 --> 00:55:36.269
upgrades will not be put into the planning model until

00:55:36.378 --> 00:55:41.030
the converter station has been given. The company has

00:55:41.039 --> 00:55:43.250
given notice to proceed for the converter station to

00:55:43.260 --> 00:55:47.728
be built. Okay. These converter stations are 5 to 7 years

00:55:47.739 --> 00:55:51.070
out and there's no reason to put that number, that

00:55:51.079 --> 00:55:55.269
planning model number immediately upon completion of

00:55:55.280 --> 00:55:57.500
an interconnection or whenever they put it into the

00:55:57.510 --> 00:56:00.628
planning model, it should be when there is certainty

00:56:00.639 --> 00:56:06.409
around that facility and the facility of a DC tie becomes

00:56:06.869 --> 00:56:10.398
fable when you put in an order and you put money down

00:56:10.409 --> 00:56:14.110
for the converter stations which cost a few billion

00:56:14.119 --> 00:56:18.599
dollars. So for those reasons, I think that PGRR105

00:56:18.648 --> 00:56:22.199
is important to pass. It's important for certainty

00:56:22.208 --> 00:56:27.148
We talk about certainty here, HVDC lines are not going

00:56:27.159 --> 00:56:30.769
to be a panacea for, we're not going to see billions

00:56:30.780 --> 00:56:33.619
of dollars of transmission upgrades for these projects

00:56:33.938 --> 00:56:36.989
They just don't make economic sense everywhere. They

00:56:37.000 --> 00:56:39.559
have to be a certain distance for them to make sense

00:56:39.898 --> 00:56:43.750
because you effectively pay for the billion dollar

00:56:43.760 --> 00:56:46.699
converter stations through the minimization of line

00:56:46.708 --> 00:56:51.519
losses. That's what makes this technology work. And

00:56:52.898 --> 00:56:55.648
again, this is another area I think like batteries

00:56:55.659 --> 00:56:58.329
The next issue we'll discuss that we don't have a whole

00:56:58.340 --> 00:57:02.030
lot of experience with and we need to learn from and

00:57:02.039 --> 00:57:05.219
finding ways to learn again. I think this is just an

00:57:05.228 --> 00:57:08.570
administrative issue and I would encourage that we

00:57:08.579 --> 00:57:13.688
give guidance to ERCOT to complete the PGRR105 process

00:57:13.699 --> 00:57:16.250
to be supportive of it and let it come to us and

00:57:16.260 --> 00:57:18.489
and let's get this issue out of the way.

00:57:20.030 --> 00:57:25.300
But um, may I pose a hypothetical? Uh,

00:57:26.989 --> 00:57:30.989
well, and before the hypothetical? Okay. (item:32:Commissioner McAdams thoughts on possible policy decision) So we kind of

00:57:31.000 --> 00:57:35.469
brought up the RFP. Um and we discussed, and in a

00:57:35.478 --> 00:57:39.429
matter of fact, I believe you said that this is certainly

00:57:39.438 --> 00:57:42.349
a policy decision of such magnitude that it warrants

00:57:42.360 --> 00:57:45.590
a rulemaking and decision on the part of the Commission.

00:57:47.639 --> 00:57:52.289
And, and so kind of my position on this broadly from

00:57:52.300 --> 00:57:56.918
step from first base is one of process. This is a major

00:57:56.929 --> 00:58:01.780
policy decision derived from a PGRR. Okay, initiated

00:58:01.789 --> 00:58:07.019
by stakeholders that has implications across a panacea

00:58:07.489 --> 00:58:11.809
of interrelated policies within the overall framework

00:58:11.820 --> 00:58:15.699
of the ERCOT system. And um and so

00:58:17.228 --> 00:58:19.559
we, we do not have a rulemaking before us. We've got

00:58:19.570 --> 00:58:25.110
a PGRR and it's a hypothetical PGRR and subject to change

00:58:25.119 --> 00:58:28.969
So there's a, there's a certain sense of prejudgment

00:58:29.648 --> 00:58:34.409
that is going on here about significant policy areas

00:58:36.269 --> 00:58:40.458
and that's concerning um that, okay. And that gets the

00:58:40.469 --> 00:58:45.208
hypothetical about how you basically accredit the,

00:58:45.219 --> 00:58:47.820
the flows across those lines because that's really

00:58:47.829 --> 00:58:49.938
what we're after at the end of the day, ERCOT is trying

00:58:49.949 --> 00:58:52.639
to ensure reliability. We're trying to efficiently

00:58:52.648 --> 00:58:56.110
size our transmission system to ensure the deliverability

00:58:56.119 --> 00:59:01.628
of power. And that reliability say Uri went uh the

00:59:01.639 --> 00:59:09.409
ground zero of Uri went 300 miles more North and, and

00:59:09.418 --> 00:59:13.030
East. Of where it eventually landed right smack dab

00:59:13.039 --> 00:59:17.418
over the heart of Texas. And it said that was now Missouri

00:59:17.860 --> 00:59:24.530
and Oklahoma and um, Louisiana, north northeast or

00:59:24.539 --> 00:59:27.309
northwest Louisiana, the bottom line gas fields in

00:59:27.320 --> 00:59:32.280
Oklahoma freeze off. And instead of the Permian in Texas

00:59:32.619 --> 00:59:38.909
and MISO and SPP are affected. And we've got 568 whatever

00:59:38.918 --> 00:59:42.159
Megawatt capacity of Southern Spirit at that time.

00:59:42.938 --> 00:59:46.539
Do we have the flows of 100% electricity happening

00:59:46.550 --> 00:59:49.019
at that time? I would assert no, we wouldn't in that

00:59:49.030 --> 00:59:51.628
hypothetical. Because MISO would have clawed their power

00:59:51.639 --> 00:59:56.050
back. All domestically, all native power generated in

00:59:56.059 --> 00:59:58.619
their footprint would have been on call to MISO to

00:59:58.628 --> 01:00:03.688
serve their loads. And as such, ERCOT would be left

01:00:03.699 --> 01:00:05.478
without that, even though it would be pretty cold here

01:00:05.489 --> 01:00:08.378
we know that our demand would be up. Uh It wouldn't

01:00:08.389 --> 01:00:12.010
be nearly as, as extreme. So that's what ERCOT is looking

01:00:12.019 --> 01:00:15.800
at. That's kind of the magnitude of the decision

01:00:15.809 --> 01:00:17.889
we're talking about. How much do we count on it and

01:00:17.898 --> 01:00:21.168
thus how, how much do we allow to be paid for it

01:00:21.179 --> 01:00:24.199
And, and the cost allocation discussion I get very

01:00:24.208 --> 01:00:26.719
nervous about because ultimately, I do not want to

01:00:26.728 --> 01:00:28.219
see um

01:00:29.938 --> 01:00:32.918
I don't want to see this conversation evolve. Because

01:00:32.929 --> 01:00:37.579
this PGRR has already instigated these type conversations

01:00:37.590 --> 01:00:40.829
within ERCOT on how generation, if generation ultimately

01:00:40.840 --> 01:00:45.309
pays for transmission upgrades. Broadly, the secret

01:00:45.320 --> 01:00:49.239
sauce of ERCOT is that load pays for those systems

01:00:49.250 --> 01:00:53.860
that help support the system. Um This thing could become

01:00:53.869 --> 01:00:58.090
a tangle overnight. It could unwind massive amounts

01:00:58.099 --> 01:01:01.199
of the framework that ultimately supports the reliability

01:01:01.208 --> 01:01:04.188
of our system and affordability of our system. And

01:01:04.199 --> 01:01:07.260
so. Can I ask you a question on your, on your hypothetical?

01:01:07.949 --> 01:01:12.199
(item:31:Commissioner Glotfelty's thoughts concerning power or gas generation) So what's the difference between power not coming across

01:01:12.208 --> 01:01:17.849
a DC tie during a Winter Storm Uri type event and a

01:01:17.860 --> 01:01:22.539
generating facility within ERCOT not generating because

01:01:22.550 --> 01:01:25.840
they can't get gas. Is there any difference? At least

01:01:25.849 --> 01:01:28.590
we have somebody to talk to. I don't have anybody to

01:01:28.599 --> 01:01:29.409
talk to in Missouri.

01:01:31.280 --> 01:01:33.728
You know, if you're thinking from a, from a molecule

01:01:33.739 --> 01:01:38.389
and a and a electron basis. It doesn't matter where

01:01:38.398 --> 01:01:44.070
that those generators are because if, if the electrons

01:01:44.079 --> 01:01:45.829
that we're trying to see in ERCOT

01:01:47.409 --> 01:01:49.250
come across that converter station,

01:01:51.000 --> 01:01:54.648
whether they're there or they're not is the same decision

01:01:55.269 --> 01:01:59.429
in my view that we have to look at every day with

01:01:59.438 --> 01:02:01.769
every generator that gets interconnected to the system

01:02:01.809 --> 01:02:04.438
Is it going to be there or is it not going to

01:02:04.449 --> 01:02:07.188
be there? And is it going to be there during the most

01:02:07.199 --> 01:02:09.099
critical time? We don't know

01:02:10.679 --> 01:02:13.909
if it backs down and if it breaks, I mean, again to

01:02:13.918 --> 01:02:16.458
your, to your hypothetical for that storm? One other

01:02:16.469 --> 01:02:22.889
thing, Commissioner Cobos. So what if we had 500 megawatts

01:02:22.898 --> 01:02:26.179
coming across the southern cross line on September

01:02:26.188 --> 01:02:29.878
6th. Would we have had to have an EEA in the

01:02:29.889 --> 01:02:33.280
South? Would we have had prices go through the roof?

01:02:33.800 --> 01:02:37.110
Probably not because we would have had more generation

01:02:37.119 --> 01:02:42.329
in the North. It gives you options, it gives you flexibility

01:02:42.619 --> 01:02:45.769
which is what we need. We don't have as, you know,

01:02:45.860 --> 01:02:51.349
we don't just have 60 or 80 big generators on our system

01:02:51.360 --> 01:02:56.429
anymore. We have hundreds and that exponentially creates

01:02:56.438 --> 01:02:59.789
the challenges for operators to anticipate what's going

01:02:59.800 --> 01:03:03.409
to happen. So adding more optionality to help them

01:03:03.418 --> 01:03:08.570
solve problems in my view is what they need and them

01:03:08.579 --> 01:03:14.688
having access to a full line from imports from DC lines

01:03:15.119 --> 01:03:18.269
is in my view, is a valuable tool. (item:32:Commissioner McAdams thoughts on control) It is a valuable

01:03:18.280 --> 01:03:21.668
tool. And, and that's why ERCOT went through such pains

01:03:21.679 --> 01:03:26.119
And I thought we had given Southern now Spirit regulatory

01:03:26.128 --> 01:03:28.918
certainty. And that was my hope after all this odyssey

01:03:28.929 --> 01:03:33.250
since 2015, you know that they're finally there. And

01:03:33.260 --> 01:03:35.619
uh then this PGRR comes out of nowhere and all of

01:03:35.628 --> 01:03:39.889
a sudden we go from 0 to 100. Um and it's, it's

01:03:39.898 --> 01:03:46.199
whipsawed. And uh but I, I would also say one of the

01:03:46.208 --> 01:03:50.559
themes of today on several issues is going to be control.

01:03:51.309 --> 01:03:54.168
What do we have control of and how do we control it

01:03:54.820 --> 01:03:59.090
Well, I know the things that were are within the boundaries

01:03:59.099 --> 01:04:01.648
of the state of Texas, South of the Red River are under

01:04:01.659 --> 01:04:03.250
the control of the State of Texas.

01:04:04.878 --> 01:04:08.429
And um, and that's an important factor and I don't

01:04:08.438 --> 01:04:11.320
I don't think you can argue against that. (item:31:Commissioner dialogue on PGRR105) Oh, I don't

01:04:11.329 --> 01:04:13.398
argue against it. I just, I think there's certainty

01:04:13.409 --> 01:04:17.500
with the way FERC has given up authority for DC lines

01:04:17.510 --> 01:04:19.340
all across. I'm not even talking about jurisdictional

01:04:19.349 --> 01:04:21.239
I'm just talking about how you can ultimately call

01:04:21.250 --> 01:04:27.579
upon command different assets within the state to behave

01:04:27.590 --> 01:04:28.619
I don't think you can do that.

01:04:30.269 --> 01:04:33.760
Under laws you can. Well, if they're available and

01:04:33.769 --> 01:04:37.168
we have found that most of these, a lot of the units

01:04:37.179 --> 01:04:40.119
around the state are having higher force outage rates

01:04:40.128 --> 01:04:45.550
and their availability is lower. So again, I'm not

01:04:45.559 --> 01:04:49.688
arguing against you. I'm telling you, my view is that

01:04:50.099 --> 01:04:55.309
PGRR105 provides optionality that it shouldn't be put

01:04:55.659 --> 01:04:59.449
that we should encourage the approval of that because

01:04:59.458 --> 01:05:03.128
these lines are valuable that ERCOT can appropriately

01:05:03.139 --> 01:05:05.898
determine when those lines should go into their base

01:05:05.909 --> 01:05:10.438
planning model, but not before notice to proceed. And

01:05:10.449 --> 01:05:14.539
then we've, we've resolved this issue not to 90% as

01:05:14.550 --> 01:05:16.860
we had done before, but to 100%. I can't hear you.

01:05:17.030 --> 01:05:20.070
Can I add a couple of things? Just clarification points

01:05:20.079 --> 01:05:22.329
I think. (item:31:Commissioner Cobos' thoughts on PGRR105) Number one, I think to Commissioner McAdams

01:05:22.340 --> 01:05:26.789
point, I mean. We've had the CCN order, the scoping

01:05:26.800 --> 01:05:29.909
project feedback from ERCOT updates, extensive updates

01:05:29.918 --> 01:05:32.119
on the completion of directives. Our final conclusion

01:05:32.128 --> 01:05:33.978
that the directives are completed. So there, there

01:05:33.989 --> 01:05:36.489
should be regulatory certainty for Southern Cross,

01:05:36.500 --> 01:05:40.898
like you said, based on the bulk of feedback, Southern

01:05:40.909 --> 01:05:45.918
Spirit, um that has been uh provided by the Commission

01:05:46.389 --> 01:05:49.878
and ERCOT. So, setting that aside now, to your point

01:05:49.889 --> 01:05:52.250
Commissioner Glotfelty, on what's the difference between

01:05:52.269 --> 01:05:57.219
a DC tie and a generator? And if the flows don't come

01:05:57.228 --> 01:06:01.059
in as imports and versus, you know, a forced outage

01:06:01.070 --> 01:06:03.699
of a generation unit, ERCOT, the difference in my mind

01:06:03.708 --> 01:06:08.369
is with a DC tie, you're building the system to accommodate

01:06:08.378 --> 01:06:10.820
the full deliverability and it doesn't come over. And

01:06:10.829 --> 01:06:13.489
that's a cost to the system that the ratepayers are

01:06:13.500 --> 01:06:15.860
going to pay for. And it could be an extensive cost

01:06:15.869 --> 01:06:18.949
because you're building for a capacity that could be

01:06:18.958 --> 01:06:22.570
you know, 2000 megawatts, 1000 megawatts. And if you

01:06:22.579 --> 01:06:24.878
don't get the import, then you have the transmission

01:06:24.889 --> 01:06:27.849
sitting there that arguably as you said, could be used

01:06:27.860 --> 01:06:30.978
to facilitate other generation and move around. But

01:06:30.989 --> 01:06:34.619
you're talking about transmission infrastructure, sizable

01:06:34.789 --> 01:06:36.898
potentially sizable transmission infrastructure to

01:06:36.909 --> 01:06:40.059
accommodate a DC tie versus one power plant that you

01:06:40.070 --> 01:06:42.599
know, has generation interconnection costs and is part

01:06:42.610 --> 01:06:44.978
of the overall ERCOT system already, right? So it's

01:06:44.989 --> 01:06:49.250
not as much transmission infrastructure costs um for

01:06:49.260 --> 01:06:52.438
a forced outage, forced out generation unit in ERCOT.

01:06:52.869 --> 01:06:58.010
My understanding ERCOT is if they were to review

01:06:58.019 --> 01:07:01.958
and Woody happy to have you clarify if I'm not capturing

01:07:01.969 --> 01:07:08.219
this quite quickly. But if were to review the DC ties

01:07:08.628 --> 01:07:12.389
under, you know PGRR105. They're going to go look

01:07:12.398 --> 01:07:13.938
at the transmission upgrades and they're just going

01:07:13.949 --> 01:07:15.949
to be like, well, these are reliability transmission

01:07:15.958 --> 01:07:17.869
upgrades and we're going to get them in reliability

01:07:17.929 --> 01:07:20.039
CCNs. And we're going to have a tough time rejecting

01:07:20.050 --> 01:07:23.039
any of those CCNs if they're under the auspices of reliability.

01:07:23.570 --> 01:07:28.389
I mean, the needs established. I've said that and so

01:07:30.239 --> 01:07:34.579
ultimately, yes, we have the ability to reject the

01:07:34.590 --> 01:07:40.760
CCN. But if their reliability transmission uh projects

01:07:40.958 --> 01:07:44.519
needs established and that, that's a higher hurdle

01:07:44.530 --> 01:07:48.679
to reject at the end of the day. So I'd, I'd, I

01:07:48.688 --> 01:07:51.168
think that, you know, we, we are facing significant

01:07:51.179 --> 01:07:54.260
costs for full liability and to Commissioner mcadam's

01:07:54.269 --> 01:08:00.228
point, these are very, there are very broad uh policy

01:08:00.239 --> 01:08:02.429
considerations that we have taken into consideration

01:08:02.780 --> 01:08:07.188
and I'm not sure that the PGRR is the appropriate avenue

01:08:07.478 --> 01:08:14.719
to um you know, have this policy impacts in our market

01:08:14.728 --> 01:08:18.548
in um you know, the, the PGRR is a reverse, of course

01:08:18.560 --> 01:08:21.189
of the precedent fine. That doesn't, you know, we,

01:08:21.199 --> 01:08:23.729
we can move away from precedent and, and look at the

01:08:23.739 --> 01:08:27.520
DC ties a little bit differently, but I don't know

01:08:27.529 --> 01:08:32.250
that the PGRR is the procedural vehicle to um institute

01:08:32.259 --> 01:08:37.000
this policy change. And ultimately, um we, we need

01:08:37.009 --> 01:08:38.569
to take a harder look at it and that's why I was

01:08:38.579 --> 01:08:40.369
proposing, you know, maybe getting some questions to

01:08:40.378 --> 01:08:42.020
see if there was some kind of middle ground between

01:08:42.029 --> 01:08:47.127
0 to 100 and so. Commission, Chairman Jackson I'm

01:08:47.139 --> 01:08:51.509
happy to hand over the mic to you at this point. Okay.

01:08:51.520 --> 01:08:54.149
Do you have any further discussion? I mean, this whole

01:08:54.319 --> 01:08:58.529
objective here was just guidance to, to ERCOT. (item:32:Commisioner Glotfelty's additional thoughts on ERCOT guidance) Yeah, I'm

01:08:58.539 --> 01:09:00.628
open to, to getting guidance from stakeholders and

01:09:00.640 --> 01:09:06.668
from, from ERCOT on this. I think that we can do that

01:09:07.279 --> 01:09:09.850
It's funny that we're asking them for guidance on something

01:09:09.859 --> 01:09:13.069
that they're asking us for guidance on and then we'll

01:09:13.079 --> 01:09:15.949
go back and ask them for guidance on something. But

01:09:16.909 --> 01:09:19.729
you know, I think this is from mine, this is just a

01:09:19.739 --> 01:09:24.270
policy issue of, of nondiscriminating treatment of

01:09:24.279 --> 01:09:26.729
different types of resources. And I, I just think that

01:09:26.739 --> 01:09:27.189
that's,

01:09:29.059 --> 01:09:32.729
you know, we have resources that come into this system

01:09:32.738 --> 01:09:37.948
and go off the system every year and that and the transmission

01:09:37.957 --> 01:09:43.699
capacity that was was built into the system for their

01:09:43.708 --> 01:09:46.159
use is still there when the generation goes away.

01:09:47.809 --> 01:09:50.769
If there was, if there was transmission capacity, excuse

01:09:50.778 --> 01:09:55.229
me, built in to the transmission system at an interconnection

01:09:55.238 --> 01:09:58.957
point for DC line for 2000 megawatts and the DC line

01:09:58.969 --> 01:10:01.118
never came. I guarantee you

01:10:02.958 --> 01:10:04.418
that a generator would site there.

01:10:06.390 --> 01:10:09.930
I hope that when you cite dispatchable generation mostly

01:10:09.939 --> 01:10:12.970
gas, it was you find gas, water transmission and you

01:10:12.979 --> 01:10:16.140
cite as close as you can to those three resources because

01:10:16.149 --> 01:10:17.329
that's what you need.

01:10:18.878 --> 01:10:22.159
And if you get the biggest one, which takes the longest

01:10:22.168 --> 01:10:24.619
time to build, which is transmission. You'll find ways

01:10:24.628 --> 01:10:27.329
to build pipelines and you'll find ways to move water

01:10:28.039 --> 01:10:31.509
(item:32:Commissioner McAdams on regulatory uncertainty) May I interject a thought? I'm staring into the audience

01:10:31.520 --> 01:10:34.819
in the eyes of Southern Spirits representatives. And

01:10:35.069 --> 01:10:37.810
all this smells like regulatory uncertainty to me.

01:10:37.819 --> 01:10:40.970
Now that we're introducing it. They're nodding. Yes.

01:10:43.458 --> 01:10:46.588
This has been a long journey. We want the DC tie, we

01:10:46.600 --> 01:10:49.279
want it, don't we? I think so. I do. It's made a

01:10:49.289 --> 01:10:53.930
true believer out of me. Um And shouldn't this PGRR 

01:10:53.939 --> 01:10:56.729
just go away for the time being and, and allow them

01:10:56.739 --> 01:10:56.958
to

01:11:00.298 --> 01:11:04.409
Bruce, I'm staring at you. (item:32:Commissioner Glotfelty on regulatory uncertainty) So what the PGRR does

01:11:04.418 --> 01:11:09.259
is the PGRR adds a certainty to the level of imports

01:11:09.270 --> 01:11:13.199
to the state into the space. Again, try to understand

01:11:13.208 --> 01:11:17.359
this. I do when you build a pipeline,

01:11:18.878 --> 01:11:21.939
you sell the capacity of the pipeline. I know, I know

01:11:21.979 --> 01:11:26.060
OK, that's the valuable component is the capacity of

01:11:26.069 --> 01:11:30.069
the pipeline. There's exporting capacity on a DC line

01:11:30.079 --> 01:11:33.020
and there's importing importing capacity on a DC line

01:11:33.029 --> 01:11:36.979
and both are you can be, you can monetize them. So

01:11:36.989 --> 01:11:41.729
if you monetize both of them to their full potential

01:11:42.338 --> 01:11:44.810
it's going to be more likely that you're going to finance

01:11:44.819 --> 01:11:49.560
a facility than not. That's why I think the certainty

01:11:49.750 --> 01:11:54.560
is important. (item:32:Commissioner Cobos on regulatory uncertainty) But I, I think part of the, the regulatory

01:11:54.569 --> 01:11:59.369
uncertainty that the PGRR creates is this sort of background

01:11:59.378 --> 01:12:01.750
cost allocation debate, right? I mean,

01:12:03.399 --> 01:12:07.989
you know, too much time in SPP and MISO I think you

01:12:08.039 --> 01:12:11.708
know, it's a real thing. It's dangerous, you know.

01:12:11.720 --> 01:12:14.979
I mean, Southern Spirit has, you know, been involved

01:12:14.989 --> 01:12:17.168
in this, in these proceedings and, you know, we finally

01:12:17.180 --> 01:12:19.250
closed down, you know, closed the project down with

01:12:19.259 --> 01:12:22.520
the directives and I think now they're, you know, based

01:12:22.529 --> 01:12:24.298
on my discussions is, you know, they don't want to

01:12:24.310 --> 01:12:27.399
get allocated any costs if, if these lines start, you

01:12:27.409 --> 01:12:30.329
know, being, you know if, if, if ERCOT start looking

01:12:30.338 --> 01:12:32.789
at DC ties from a reliability perspective and transmission

01:12:32.798 --> 01:12:36.798
upgrades are needed, um they've invested in their existing

01:12:36.810 --> 01:12:39.819
infrastructure for their project to, to provide, you

01:12:39.829 --> 01:12:43.449
know, over 500 megawatts of power. If ERCOT starts looking

01:12:43.458 --> 01:12:46.109
at DC ties with a different lens and the reliability

01:12:46.479 --> 01:12:49.298
and transmission upgrades are needed, you know, their

01:12:49.310 --> 01:12:51.140
their concern is like we don't wanna have to pay for

01:12:51.149 --> 01:12:54.319
that if cost allocation comes into play and, and I

01:12:54.329 --> 01:12:57.739
mean, they're, they can move forward and, and build

01:12:57.750 --> 01:13:02.270
their, their line. And ultimately, um you know, to

01:13:02.279 --> 01:13:05.869
your point on, on imports, another factor I wanted

01:13:05.878 --> 01:13:09.159
to raise was the fact that, you know, there's a lot

01:13:09.168 --> 01:13:11.649
that goes into a decision to import, I believe. And

01:13:11.659 --> 01:13:14.479
that is well, are you gonna actually make money? Right

01:13:14.489 --> 01:13:18.409
in, in true scarcity, right, winter storm area? I mean

01:13:18.418 --> 01:13:20.668
if you're able to move power, of course, you're gonna

01:13:20.680 --> 01:13:25.020
capture the higher uh scarcity pricing, but there could

01:13:25.029 --> 01:13:29.649
be times where, you know, the low cost renewable generation

01:13:29.659 --> 01:13:33.789
will undercut the price of imports and it won't be

01:13:33.798 --> 01:13:37.310
economically sensible to send the power in and at a

01:13:37.319 --> 01:13:39.958
time where we may need it, but there are renewables

01:13:39.970 --> 01:13:42.899
in the area that are cheaper and they're going to undercut

01:13:42.909 --> 01:13:45.298
the price. So there's just a lot of factors to consider

01:13:45.588 --> 01:13:48.060
And I think that's what ultimately, besides, you know

01:13:48.128 --> 01:13:52.560
uh regulatory uh governmental control on the other

01:13:52.569 --> 01:13:55.500
side of the fence, there's also economic factors on

01:13:55.509 --> 01:13:58.890
our end that impact the full deliverability of a DC

01:13:58.899 --> 01:14:01.770
tie. And we just don't, we, we, we can't for certain

01:14:01.779 --> 01:14:05.668
ensure that we're going to get 100% uh full deliverability

01:14:05.680 --> 01:14:08.850
of the DC tie. But we certainly would have to build

01:14:08.859 --> 01:14:11.918
a system to ensure that under this PGRR. And that,

01:14:11.930 --> 01:14:15.338
that's where I, I have concerns. You know, I mean I

01:14:15.350 --> 01:14:18.489
would, I like to optimize them. Do we, do I like DC

01:14:18.500 --> 01:14:20.958
ties that to move power and sure, I mean, we, we've

01:14:20.970 --> 01:14:24.239
had, we've had some DC ties for a while and I think

01:14:24.250 --> 01:14:27.350
if it makes good sense for the DC tie investment in Texas

01:14:27.359 --> 01:14:31.279
and bringing more imports, great. But I, I just. I,

01:14:31.289 --> 01:14:35.159
I have concerns with the PGRR um and the implications

01:14:35.168 --> 01:14:38.119
uh policy implications for our market and also from

01:14:38.128 --> 01:14:41.899
a cost perspective. And so I, my guidance would be

01:14:41.909 --> 01:14:45.439
um to not move forward with the PGRR for full deliverability

01:14:45.449 --> 01:14:49.600
But if the Commission wants to explore a middle ground

01:14:49.989 --> 01:14:53.918
then I would be open to exploring a middle ground that

01:14:53.930 --> 01:14:57.979
would make sense um to create some option. So some

01:14:57.989 --> 01:15:01.619
more optimization of the DC ties if the desire of the

01:15:01.628 --> 01:15:06.239
Commission is not to continue to zero out um but find

01:15:06.250 --> 01:15:11.259
some, some way of ensuring a little bit more deliverability

01:15:11.770 --> 01:15:15.088
than just flat out zero. (item:32:Comissioner Glotfelty on path forward) I'd be happy to work with

01:15:15.100 --> 01:15:16.918
you on that. I don't know what the path forward is

01:15:16.930 --> 01:15:19.418
on this, but you know, I think that

01:15:21.829 --> 01:15:25.989
zero is unacceptable in my opinion. I think 100 in

01:15:26.000 --> 01:15:29.619
my opinion, 100% is not different from any other generating

01:15:29.628 --> 01:15:32.338
facility. So I don't have a problem with that, but

01:15:32.350 --> 01:15:35.850
I'm a believer in DC lines. I'm a believer in the functionality

01:15:35.859 --> 01:15:38.409
and the optionality of them. So whatever can get us

01:15:38.418 --> 01:15:43.789
closer to their use and benefit in our state. I'm I'm

01:15:43.798 --> 01:15:48.399
for so I don't know if we want to delay

01:15:49.909 --> 01:15:54.100
a recommendation on this until we can have a discussion

01:15:54.109 --> 01:15:57.149
a stakeholder meeting or further discussion with ERCOT.

01:15:58.359 --> 01:16:01.659
but I'm open to doing that and deferring a decision

01:16:01.668 --> 01:16:02.708
on this or a

01:16:04.239 --> 01:16:05.128
a uh

01:16:07.489 --> 01:16:12.180
not a direct guidance, guidance on this until we can

01:16:12.189 --> 01:16:15.159
have some further discussions. So Commissioner Cobos

01:16:15.199 --> 01:16:17.458
didn't you recommend putting, you said you would put

01:16:17.470 --> 01:16:19.640
together a list of questions. (item:32:Commissioner Cobos on path forward) I can work with Commissioner Glotfelty

01:16:20.039 --> 01:16:21.939
to put, put together some questions. I'm just trying

01:16:21.949 --> 01:16:24.029
to think procedurally where we're at with the PGRR

01:16:24.039 --> 01:16:28.680
right? It's tabled at TAC. And so if we were to give guidance

01:16:28.689 --> 01:16:32.869
on finding a middle ground between zero and 100 ultimately

01:16:32.878 --> 01:16:36.128
after stakeholder feedback, that wouldn't fit within

01:16:36.140 --> 01:16:40.560
the confines of the bigger um PGRR105 introduced by Rainbow

01:16:40.569 --> 01:16:45.548
And I mean, essentially the PGRR doesn't if, if we

01:16:45.560 --> 01:16:47.689
were to come up with the middle ground that we were

01:16:47.699 --> 01:16:52.220
comfortable with, then the PGRR would need to go away

01:16:52.229 --> 01:16:54.329
And ERCOT would probably need to introduce a PGRR

01:16:54.338 --> 01:16:57.048
that was requested by the Commission to institute a

01:16:57.060 --> 01:17:00.939
middle ground because I don't think the PGRR105 introduced

01:17:00.949 --> 01:17:04.039
again by, by a stakeholder would be the appropriate

01:17:04.048 --> 01:17:07.338
vehicle to carry our guidance forward. If ultimately

01:17:07.350 --> 01:17:09.668
we want to be between zero and 100. Does that make

01:17:09.680 --> 01:17:12.088
sense? But weren't you suggesting that maybe the first

01:17:12.100 --> 01:17:14.909
step was to put the questions together and see if even

01:17:14.918 --> 01:17:18.500
that was an opportunity. (item:32:Ramya Ramaswamy on path forward) With all due respect, I have

01:17:18.509 --> 01:17:22.270
not had a chance to talk with Connie. But maybe from

01:17:22.279 --> 01:17:24.699
my understanding, from what you're saying is, we could

01:17:24.708 --> 01:17:29.208
open a project and post these questions um and see

01:17:29.220 --> 01:17:32.250
what the stakeholder process within the Commission

01:17:32.338 --> 01:17:35.350
can give us an answer to the questions that you pose

01:17:35.569 --> 01:17:39.069
while the PGRR remains stabled at.

01:17:41.100 --> 01:17:45.798
(item:32:Commissioner Cobos' thoughts on PGRR) But ultimately, my point is if we come back between

01:17:45.810 --> 01:17:47.939
if we get stakeholder comment and we agree in a path

01:17:47.949 --> 01:17:50.609
forward, a process forward to explore between zero

01:17:50.619 --> 01:17:55.279
and 100. Is that PGRR tabled TAC going to be the

01:17:55.289 --> 01:17:58.359
appropriate vehicle to carry our ball forward when

01:17:58.369 --> 01:18:01.109
it's been introduced by a stakeholder and it's 100%

01:18:01.119 --> 01:18:03.479
deliverability, they would have to agree to go modify

01:18:03.489 --> 01:18:06.509
it. And, but is that the appropriate vehicle to carry

01:18:06.520 --> 01:18:08.680
I think we'll have to, I think we'll just have to see

01:18:08.689 --> 01:18:11.220
I don't think we can prejudge what that is at this

01:18:11.229 --> 01:18:14.430
point in time. We can always, you know, them to, to

01:18:14.439 --> 01:18:18.529
modify it. We can, you know, approve, we can remand

01:18:18.539 --> 01:18:20.829
it with instructions. We can, I mean, we, I think we

01:18:20.838 --> 01:18:24.659
have flexibility there. I don't know if we could order

01:18:24.668 --> 01:18:29.168
Rainbow to go institute our guidance. But I just feel

01:18:29.180 --> 01:18:31.270
that if we found a middle ground, the better, the better

01:18:31.279 --> 01:18:33.220
thing to do would be to figure out if we want to

01:18:33.229 --> 01:18:35.918
put part of it in roll and part of it in ERCOT

01:18:35.930 --> 01:18:38.970
protocol PGRR or if it just needs to go back to an

01:18:38.989 --> 01:18:41.689
ERCOT sponsored PGRR to move that ball forward rather

01:18:41.699 --> 01:18:45.979
than try to, you know, kind of wedge it into the PGRR105

01:18:45.989 --> 01:18:51.418
for Rainbow to carry forward. (item:32:PUC Staff's Connie Corona summarizes the Chairwoman & Commissioners discussion) I think um what we're

01:18:51.430 --> 01:18:55.829
hearing today is that you all would like to explore

01:18:55.838 --> 01:19:00.310
this policy issue by uh putting out some questions

01:19:00.319 --> 01:19:04.168
for stakeholder comment and then developing a Commission

01:19:04.250 --> 01:19:10.470
policy and then stakeholders would then react to that

01:19:10.479 --> 01:19:16.319
or potentially ERCOT. Um using, using the procedural

01:19:16.329 --> 01:19:19.159
uh methods available to them in the ERCOT stakeholder

01:19:19.168 --> 01:19:23.520
process. So essentially that's what you've described

01:19:23.529 --> 01:19:27.970
Commissioner Cobos. But I would say tabled. I was just gonna say in

01:19:27.979 --> 01:19:30.250
your mind, what's the time frame for this? Because

01:19:30.588 --> 01:19:34.449
the goal in all of these directives was to create certainty.

01:19:34.759 --> 01:19:37.930
If we're creating uncertainty for another three months

01:19:37.939 --> 01:19:40.869
six months, nine months I think we're doing a disservice.

01:19:41.000 --> 01:19:43.310
Yeah, I hear you. (item:32:Commissioner Cobos' additional thoughts on path forward) And, and you know, that's coupled

01:19:43.319 --> 01:19:46.939
with the tremendous work load we have and I mean, we

01:19:46.949 --> 01:19:50.149
could put our questions this next month in December.

01:19:50.159 --> 01:19:53.958
And then come back and talk about it, you know. But,

01:19:53.970 --> 01:19:57.149
but also, you know, the certainty to your point, I

01:19:57.159 --> 01:19:57.668
mean,

01:20:00.298 --> 01:20:02.529
I know you guys want certainty and, and we're trying

01:20:02.539 --> 01:20:03.958
to do that and I think we've done a lot of it

01:20:03.970 --> 01:20:08.850
already in the prior dockets. Um but I mean, other

01:20:08.859 --> 01:20:12.069
shovel, you know, right now being used to bring in

01:20:12.079 --> 01:20:14.869
the DC ties right now, they take years to build. Um

01:20:14.878 --> 01:20:17.439
We want to provide policy certainty and, and we can

01:20:17.449 --> 01:20:19.310
probably do it in the first quarter of this next year

01:20:19.319 --> 01:20:22.739
once we get comments and deliberate, um you know, January

01:20:22.750 --> 01:20:25.628
February. But I just want to be mindful of the fact

01:20:25.640 --> 01:20:27.289
that, you know, we're trying to provide certainty in

01:20:27.298 --> 01:20:30.430
a lot of areas right now. And, and I and I will

01:20:30.439 --> 01:20:33.020
commit to developing the questions and getting stakeholder

01:20:33.029 --> 01:20:36.470
feedback and taking action as expeditiously as possible

01:20:36.479 --> 01:20:39.970
But I, I just, um, can we, can we commit that? We'll

01:20:39.979 --> 01:20:41.909
bring this back up at the 1st January meeting

01:20:43.470 --> 01:20:45.399
and you'll work on the questions and kind of give us

01:20:45.409 --> 01:20:47.619
an idea and then we can go from there. We, we can

01:20:47.628 --> 01:20:49.159
start talking about it in January. I'm just wondering

01:20:49.168 --> 01:20:51.489
like, you know, we get the comments back and process

01:20:51.500 --> 01:20:54.409
them over the holidays, you know, and then we're back

01:20:54.418 --> 01:20:58.029
in, I mean, by February, we could start the discussion

01:20:58.039 --> 01:21:00.509
on the 18th and maybe continue it to the 2nd. Is

01:21:00.520 --> 01:21:03.029
that ok? Because of the intervening holidays and everything.

01:21:03.250 --> 01:21:05.569
I think what you were saying is get the questions together

01:21:05.579 --> 01:21:08.640
and get them back in January. (item:32:Commissioner Glotfelty's additional thoughts on path forward) I think get them out

01:21:08.649 --> 01:21:11.838
I think the, the universal market participants are

01:21:11.850 --> 01:21:14.579
probably they've already commented on the PGRR in

01:21:14.588 --> 01:21:19.048
the process and they'll comment some more. I don't

01:21:19.060 --> 01:21:22.149
think it takes them that long to comment. And I think

01:21:22.159 --> 01:21:27.949
that yeah I mean, this is not a huge universe but

01:21:28.048 --> 01:21:30.909
we should give them all the opportunity. And if we

01:21:30.939 --> 01:21:33.479
say that, you know, comments are due by the end of

01:21:33.489 --> 01:21:37.520
December and we evaluate them and have a discussion

01:21:37.529 --> 01:21:40.899
about this in January and try to resolve this in January

01:21:40.909 --> 01:21:42.989
so we can give our guidance to ERCOT. I think that

01:21:43.000 --> 01:21:46.060
would be appropriate. Yeah, I just think that even

01:21:46.069 --> 01:21:48.279
though the stakeholders provided comments in the PGRR

01:21:48.449 --> 01:21:52.069
what we're asking for is a different sort of process

01:21:52.079 --> 01:21:55.359
and a middle ground, right? So it's kind of a new idea

01:21:56.020 --> 01:21:58.729
And so, but, you know, we'll get the questions out

01:21:58.739 --> 01:22:00.850
in December, we'll get them back. (item:32:Commissoner McAdams additional thoughts on path forward) To the universal

01:22:00.859 --> 01:22:04.168
stakeholders is going to grow based on that. I mean

01:22:04.180 --> 01:22:08.479
this is now a live issue at the Commission under a

01:22:08.489 --> 01:22:12.048
project potentially, potentially. Yes, we'll open

01:22:12.069 --> 01:22:15.713
a project. And so I think you're going to hear of concerns

01:22:15.725 --> 01:22:18.694
about potential second order effects or don't charge

01:22:18.704 --> 01:22:20.524
me money, you're going to get a lot of that. And you're

01:22:20.534 --> 01:22:23.354
also going to get other generators that say, oh no

01:22:23.364 --> 01:22:25.875
don't build out their capacities because they're going

01:22:25.884 --> 01:22:28.314
to be competing against me. And I don't want those

01:22:28.324 --> 01:22:31.194
guys competing in my mind. I'm going to see that. So

01:22:32.435 --> 01:22:35.503
we know what's going to be said. (item:32:Commissioner Cobos views on ERCOT guidance) Look I mean, I think

01:22:35.515 --> 01:22:38.414
that the whole point here I think. I'm, I'm from my

01:22:38.423 --> 01:22:41.704
perspective. And Chair Jackson we haven't let you in on this.

01:22:41.713 --> 01:22:45.548
But if, if what ERCOT needs today is guidance on how

01:22:45.560 --> 01:22:49.979
we feel about PGRR105. My, from my perspective is

01:22:49.989 --> 01:22:53.310
I'm not comfortable with it. And so you can do whatever

01:22:53.319 --> 01:22:55.579
you want with all our feedback. But it's, but what

01:22:55.588 --> 01:22:58.890
I'm trying to do here is provide a path forward to

01:22:58.899 --> 01:23:02.279
try to address some of your interests in the middle

01:23:02.289 --> 01:23:04.409
ground, right? And try to find a middle ground of how

01:23:04.418 --> 01:23:07.329
we can maybe do this in a way where there's a balanced

01:23:07.338 --> 01:23:11.239
approach where it's not zero and not 100. But we take

01:23:11.250 --> 01:23:15.470
a balanced approach in trying to optimize imports from

01:23:15.479 --> 01:23:19.449
DC ties. But why, why shouldn't it be 100? That's what

01:23:19.458 --> 01:23:22.798
I don't get is every generator when they interconnect

01:23:22.810 --> 01:23:26.609
with our state gets 100 every generator.

01:23:28.239 --> 01:23:31.039
But it doesn't include all the transmission infrastructure

01:23:31.048 --> 01:23:32.668
potentially that would be required to facilitate a

01:23:32.680 --> 01:23:37.909
2000 Megawatt DC tie into Texas. (item:32:Commissioner Glotfelty on deliverability) If you built a 2000 Megawatt

01:23:37.918 --> 01:23:40.029
generator in the state and went through the interconnection

01:23:40.039 --> 01:23:45.449
process. You would get 2000 megawatts of deliverability.

01:23:47.100 --> 01:23:50.390
At all times, at all times. You can't say at all times

01:23:50.399 --> 01:23:53.229
on any of these things because there are, there are

01:23:53.239 --> 01:23:58.199
too many facets of the system, but you get a large

01:23:58.208 --> 01:24:01.489
portion of that deliverability in in other markets

01:24:01.500 --> 01:24:04.579
like SPP and MISO you're not buying deliverability

01:24:04.899 --> 01:24:07.479
We've said consumers are going to pay for all of that

01:24:08.359 --> 01:24:11.149
but you're giving them the ability to inject a large

01:24:11.159 --> 01:24:15.119
portion of their project. And as a DC tie developer,

01:24:15.310 --> 01:24:18.869
these are the battles that we fought in 11 different

01:24:18.878 --> 01:24:22.039
states. What's the difference between a generator and

01:24:22.048 --> 01:24:25.409
a converter station? You know, in the eyes of an individual

01:24:25.418 --> 01:24:30.319
and a regulator, a lot in the eyes of a electric power

01:24:30.329 --> 01:24:33.859
system? Nothing. (item:32:Commissioners dialogue on deliverability) So, so the distinction is

01:24:35.708 --> 01:24:38.750
I think it's fair to say when we approve those, we

01:24:38.759 --> 01:24:42.779
say we expect you to provide what, what you say the

01:24:42.789 --> 01:24:45.250
value. And then you trip off line and there you have

01:24:45.259 --> 01:24:48.439
a tube leak and guess what? But, but when it's brand

01:24:48.449 --> 01:24:51.708
new and nice and shiny, we expect you to provide that

01:24:51.779 --> 01:24:54.770
and that's when you're interconnected. You're right. But listen, I

01:24:54.779 --> 01:24:58.579
had, when I was at Calpine, we built a 501 h turban

01:24:58.588 --> 01:25:01.310
down at Magic Valley and it didn't work for 9 months

01:25:01.319 --> 01:25:03.369
or 10 months. Then law suit, you know.

01:25:05.088 --> 01:25:08.989
I mean. The transmission was built and our generator 

01:25:09.000 --> 01:25:11.418
didn't work, so. I know.

01:25:12.930 --> 01:25:15.069
I think what we're looking for here is a path forward

01:25:15.079 --> 01:25:15.930
right? (item:32:Connie Corona suggestion to Commissioners concerning 2nd Open Meeting in 2024) So

01:25:17.640 --> 01:25:21.600
Commissioners, if I may make a suggestion? The 2nd Open Meeting

01:25:21.649 --> 01:25:27.128
of 2024 occurs on February 1st. So that's pretty early

01:25:27.378 --> 01:25:30.640
um, in the first quarter as Commissioner Cobos alluded

01:25:30.649 --> 01:25:35.918
to. Um, Staff will work with your respective offices

01:25:35.930 --> 01:25:39.069
to develop some questions, get some comments back from

01:25:39.079 --> 01:25:42.609
stakeholders and prepare an analysis for you to discuss

01:25:42.619 --> 01:25:47.750
at that February 1st meeting. Is that acceptable? It's

01:25:47.759 --> 01:25:52.958
acceptable to me? Yes. Yes. Okay. Thank you. Okay. So that will. So

01:25:52.970 --> 01:25:55.458
does that mean this is tabled right now or just not

01:25:55.548 --> 01:25:57.759
I guess it's not. That means we're moving forward with

01:25:57.779 --> 01:26:02.239
a with, a with, a with, a policy and some questions.

01:26:05.659 --> 01:26:07.588
Okay. (item:59:Chairwoman Jackson pauses Open Meeting, to hold Closed Session) Well, we had kind of said at the top of the

01:26:07.600 --> 01:26:10.189
hour that we would go into Closed Session somehow around

01:26:10.199 --> 01:26:14.088
1130. Um, the next Item up I think is going to have

01:26:14.100 --> 01:26:18.689
considerable discussion. And so I would suggest that

01:26:18.699 --> 01:26:24.239
um, we adjourn and go into um Closed Session. Now

01:26:24.859 --> 01:26:29.759
and um so having convened in a duly noticed Open Meeting.

01:26:29.770 --> 01:26:35.619
The Commission will now at 11:09 on November 30, 2023,

01:26:35.628 --> 01:26:38.298
hold a Closed Session to discuss matters pursuant to

01:26:38.310 --> 01:26:44.399
Chapter 551 of the Texas Government Code Sections 551.071.

01:26:44.409 --> 01:26:49.458
And we'll be back in probably 30 minutes.