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Texas Strawman Would Add New Provisions Related To Evaluation of RMR Agreements

October 11, 2016

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Copyright 2010-16 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

Staff of the Public Utility Commission of Texas filed a strawman proposal to, among other things, propose new provisions related to the evaluation of RMR service.

Staff sought comment on the following questions:

• Is capacity subject to RMR service required to be included in the calculation of the share of installed generation capacity described in P.U.C. Subst. R. §25.401 and set forth in PURA §39.154? If it is not required, should this capacity be included in the calculation?

• Should certain categories of resources (e.g., wind generation resources or resources within a private use network that participate in ancillary services or energy markets) be exempt from consideration for RMR service? For resources within a private use network, how does this impact P.U.C. Subst. R. §25.361(f) and PURA §39.151(l)?

• Should all RMR agreements be subject to approval by the Commission or the ERCOT Board of Directors?

• Assuming there is a reliability need, should ERCOT have the discretion not to enter into an RMR agreement or select any RMR alternative in consideration of the cost of the RMR service or RMR alternative and the likelihood that such a reliability event will occur?

The strawman would require that ERCOT shall develop criteria to consider the relative costs and reliability impacts of alternatives to an agreement with a generation entity to provide RMR service. If an RMR alternative provides cost savings in comparison to the RMR service, ERCOT may select the RMR alternative in place of the RMR service even if the RMR alternative does not provide an equivalent reliability contribution. Additionally, ERCOT may determine that no RMR service or RMR alternative is warranted when considering the likelihood of the reliability need, the strawman provides

The strawman would require that generating units, except in cases of forced outages, provide ERCOT with 180 days notice prior to the date on which it intends to cease or suspend operation of a generation resource for a period of greater than 180 calendar days.

The strawman would also provide that ERCOT shall maintain the confidentiality of a notification to suspend operations until it issues a final determination of the need for RMR service. This determination shall be made within 60 days of ERCOT's receipt of the notification to suspend operations, the strawman provides

ERCOT shall have 120 days after issuing its final determination to enter into an agreement with the generation entity for RMR service, the strawman provides

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