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ERCOT Seeks To Defer Consideration Of "State of Charge" NPRR For Energy Storage Beyond Dec. 14 Open Meeting
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ERCOT filed a letter with the Texas PUC requesting that the PUC defer consideration of Nodal Protocol Revision Request (NPRR) 1186,
Improvements Prior to RTC+B Project for Better ESR State of Charge Awareness, Accounting,
and Monitoring, beyond the Dec. 14 open meeting
As previously reported, Commissioners had raised several concerns with the NPRR at the most recent open meeting and had deferred consideration until the Dec. 14 meeting. See background here
ERCOT said that, as a result of the Commissioner discussion at the last open meeting, ERCOT is in the process of working through the issues
raised in that discussion and is preparing a presentation to the Commission to provide greater detail
and explanation on the following topics:
• Why near-term Energy Storage Resource (ESR) growth requires adoption of explicit and
enforceable State of Charge (SOC) requirements;
• Real-world examples of SOC deficiencies;
• Real-world examples of Ancillary Service performance failures due to SOC deficiencies;
• How NPRR1186 effectively addresses these risks while still retaining some flexibility;
• Potential reliability and market consequences if NPRR1186 is not adopted;
• How Ancillary Service responsibilities may be moved from one Resource to another within
a QSE or sub-QSE;
• An explanation of the relationship between NPRR1186 and NPRR1209, Board Priority –
State of Charge Ancillary Service Failed Quantity Allocations under NPRR1149; and
• A comparison of the existing capacity compliance framework to the framework of
NPRR1186.
"Given the time required for gathering this information and assembling it into an appropriate
format, ERCOT is concerned that it may not be able to file this presentation in time to allow careful review ahead of the Commission’s December 14, 2023 Open Meeting. To ensure ERCOT can
provide the best information possible, and to allow the Commission and other parties a reasonable
opportunity to review, ERCOT respectfully requests that the Commission defer consideration of
NPRR1186 to its January 18, 2024 Open Meeting. ERCOT commits to file its presentation with
the Commission no later than January 4, 2024. This will allow the Commission and parties a full
two weeks to review ERCOT’s materials ahead of the January 18, 2024 Open Meeting," ERCOT said
"While ERCOT seeks urgent resolution of this NPRR and regulatory certainty for ESRs,
ERCOT also wants to ensure it has responded to each of the concerns raised at the last Open
Meeting discussion. ERCOT can confirm that deferring this discussion to the January 18, 2024
Open Meeting would not delay any of ERCOT’s other market initiatives, including Real-Time Co-optimization," ERCOT said
Docket No. 54445
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December 11, 2023
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Copyright 2010-23 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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