Battery Storage Developer Seeks Emergency Texas PUC Order, Alleges Co-ops Not Providing ESI-ID Needed For Project To Commence Service, In Violation Of ERCOT Protocols

July 12, 2023

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Reporting by Paul Ring • ring@energychoicematters.com

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Wolf Tank Storage LLC ('Wolf Tank') filed a request for emergency relief at the Texas Public Utility Commission seeking that the PUC issue an emergency order for South Texas Electric Cooperative, Inc. ('STEC') and Medina Electric Cooperative, Inc. ('Medina') to provide an ESI ID to effectuate Wolf Tank's immediate and full access to the ERCOT grid

Wolf Tank owns a 150 MW standalone, dispatchable battery storage facility located in Webb County that Wolf Tank states is, "fully constructed and operational," but that Wolf Tank alleges, "is being prevented from commencing commercial operations and being available to provide dispatchable energy and ancillary services to meet critical summer peak loads[.]"

Wolf Tank alleged, "South Texas Electric Cooperative, Inc. ('STEC') and its member Medina Electric Cooperative, Inc. ('Medina') are preventing the Electric Reliability Council of Texas, Inc. ('ERCOT') from using an Electric Service Identifier1 ('ESI ID') to measure the auxiliary load at the Wolf Tank facility."

Wolf Tank alleged, "ERCOT has found that STEC’s and Medina’s actions violate the ERCOT Protocols and indicated that it will refer the issue to the Commission’s Division of Compliance and Enforcement ('DICE')."

Wolf Tank alleged, "Wolf Tank has taken the necessary steps for operation in ERCOT, including signing a retail service contract with Medina, the exclusive retail service provider in the project’s area and a STEC member cooperative, to provide retail service for auxiliary power to the facility site. Wolf Tank is interconnected with the ERCOT grid, has successfully energized and synchronized the resource and completed all testing, and is ready to go into commercial operation as soon as the ESI ID is issued. When Wolf Tank met with ERCOT on May 30, 2023, ERCOT informed Wolf Tank that STEC, without any notice to Wolf Tank, had effectively 'revoked' the ESI IDs previously assigned by STEC to Wolf Tank’s auxiliary load. Since that time, despite Wolf Tank’s tireless efforts to resolve the matter, STEC has steadfastly refused to make an active ESI ID available for the Wolf Tank auxiliary power service."

Wolf Tank alleged, "On July 6, 2023, via email, ERCOT notified STEC, Medina and Wolf Tank 'that Medina has an obligation to assign an ESI ID for the Wolf Tank site pursuant to Protocols Sec. 16.6(4), which requires an Electric Cooperative to assign an ESI ID to each Non-Opt-In Entity (NOIE) wholesale point of delivery.' ERCOT further explained that 'Medina’s continuing refusal to provide an ESI ID for the Wolf Tank site violates the Protocols.' ERCOT instructed Medina to issue the needed ESI ID within five business days of the July 6 email—by July 13."

Wolf Tank alleged, "As of this [July 12] filing, Medina and STEC have not complied with this instruction from ERCOT. Wolf Tank understands that DICE will address STEC’s and Medina’s Protocol violations, but the DICE process does not provide the urgent relief Wolf Tank needs to get Wolf Tank’s dispatchable storage resource to commercial operations without further delay in a period where the grid is under the stress of summer peak loads. Thus, this request for emergency relief is necessary to prevent continued Protocol violations while the DICE investigation proceeds."

Wolf Tank alleged, "By denying a new wholesale competitor access to the ERCOT wholesale market, STEC and Medina have impermissibly acted in a manner to constrain wholesale competition in violation of PURA and Commission Rules ... By preventing the operation of 150 MW of new dispatchable battery storage capacity on the ERCOT system, in an area where STEC and its affiliate own generation, STEC and Medina have materially reduced wholesale competition and have interfered with the efficient operation of the ERCOT market."

Wolf Tank alleged, "Their [the co-ops] action is particularly troubling given that STEC and Medina both consented more than one year ago to the metering configuration. Moreover, the Wolf Tank configuration is consistent with well-established energy storage metering configurations used throughout ERCOT and was later approved by ERCOT. In reliance on these approvals, Wolf Tank made significant investment in the construction and installation of facilities. As a result, allowing STEC and Medina to now withhold grid access for Wolf Tank in this manner not only harms Wolf Tank, but it also harms the ERCOT market, including consumers, because this anti-competitive conduct sends a signal to future investors that ERCOT is not open to new dispatchable resources, and that those investors will not be able to rely on the enforceability of existing rules and laws."

Docket 55224

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