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ERCOT Seeks Emergency Authority for New EILS Procurement
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February 28, 2011
ERCOT has filed an emergency petition with the PUCT to allow ERCOT to procure additional Emergency Interruptible Load Service (EILS) under a new contract period, and without the otherwise required 90 days notice, due to the exhaustion of allowable deployments of EILS resources in the current period during the February 2 emergency event (39191).
Under the EILS program, an EILS resource shall be subject to a maximum of two deployments per EILS contract period, lasting no more than a total of eight hours per contract period, unless an EILS deployment is still in effect when the eighth hour lapses, in which case EILS deployment shall continue until ERCOT releases the EILS resource. EILS resources may return to service only after being released by ERCOT.
Based on these deployment limitations, ERCOT said that it is no longer permitted to deploy EILS Loads for the remaining portion of the EILS Contract Period covering February 1 through May 31, 2011, after deploying EILS resources for 28 hours during the February 2 emergency event.
"ERCOT did not envision that a 28-hour deployment would occur this early in an EILS Contract Period - thereby resulting in the unavailability of any EILS capacity going forward for the remaining portion of the four-month Contact Period. ERCOT has continuing operational concerns for the remainder of the EILS Contract Period, and desires to acquire a new supply of EILS capacity as soon as possible," ERCOT said.
ERCOT specifically requested that the Commission modify Subst. R. 25.507 in order to provide ERCOT with the flexibility to create a new EILS Contract Period covering April 1 through May 31, 2011.
"ERCOT desires to have all operational tools available before reaching that final step in the [emergency event] process - i.e. shedding firm Load. The 'shoulder months' of April and May can pose a unique set of operational challenges for ERCOT if extreme weather occurs. Historically, a sizable amount of generation capacity is Off-line during the 'shoulder months' of the year as a result of Planned Outages ... The potential for extreme weather exists in the spring, especially during the months of April and May, and ERCOT must be prepared to respond to any extreme weather situation. Although EILS is not considered an operating reserve such as Responsive Reserves or Nonspin Reserves, ERCOT does view EILS as a valuable operational tool and it must be able to have all operational tools readily available within its arsenal for deployment," ERCOT said.
Even if the emergency rule is adopted, ERCOT said that it may not procure EILS capacity if the MWs offered, "[are] not priced reasonably and therefore deemed sufficient to provide ERCOT with a useful operational tool."
ERCOT requested that the PUCT adopt ERCOT's proposed changes to Subst. R. 25.507 on an emergency basis, "to avoid or minimize the imminent peril to the public health, safety, or welfare of the ERCOT Region community that could occur due to an emergency Load shedding event."
ERCOT said that the Commission would need to make a determination on its petition no later than the March 24th Open Meeting in order to allow ERCOT to move forward with procurement of EILS capacity by April 1, 2011.
ERCOT also reported that although ERCOT will not know the performance of EILS Loads for the February 2, 2011 emergency event until mid to late March 2011, ERCOT believes that the deployment of approximately 467 MWs of EILS Loads most likely mitigated the need to direct TDSPs to shed additional firm Load throughout the day on February 2.
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