Texas Retail Electric Providers Oppose Sought New Mandates For More Frequent Reporting Of Dynamic Pricing, Demand Response Info To ERCOT

May 22, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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The Retail Electric Provider (REP) Coalition has filed comments at ERCOT opposing, as filed, Nodal Protocol Revision Request (NPRR) 933 (Reporting of Demand Response by Retail Electric Providers and Non-Opt-In Entities, submitted by ERCOT) which would include in the protocols a specific mandate for retail electric providers to share information about their demand response and price responsive programs with ERCOT, and would also increase the frequency of required reporting by REPs

The NPRR had been first exclusively reported by RetailEnergyX.com (story here)

In comments on the NPPR, the REP Coalition said that, "We strongly support ERCOT’s effort to provide transparency into Load response capability in the ERCOT region by quantifying the level of Demand response participation and capability. Members of the REP Coalition offer dynamic pricing and Demand response products in the competitive retail electric market. The availability of those products contributes towards sustaining a reliable electric grid, a critical objective for all Market Participants."

However, the REP Coalition opposed the significant expansion in reporting sought by ERCOT

Currently, REPs and Non Opt-In Entities (NOIEs) offering dynamic pricing and Demand response products and programs annually submit information to ERCOT about those offerings for the purpose of an annual ERCOT Demand response report. This publicly available report summarizes those products and programs, and calculates the number of megawatts (MW) enrolled in those offerings in the ERCOT Region.

The proposed amendments would require affected REPs and NOIEs to submit the requested information on a quarterly basis, as opposed to the current annual basis. Although the frequency of REP and NOIE reporting quadruples under the proposal, the ERCOT Demand response report in Section 3.10.7.2.1 remains an annual requirement, the REP Coalition noted

The REP Coalition said that, under the current annual reporting, "REPs have devoted a substantial amount of time and effort to prepare and compile their responses to ERCOT’s annual request."

The REP Coalition said that, in this process, each REP must:

• Sort each Electric Service Identifier (ESI ID) enrolled in each of the ERCOT- defined product categories;

• Submit the initial file via North American Energy Standards Board (NAESB); and

• If it receives an error file from ERCOT, re-submit a full corrected file for completion.

"The REP Coalition opposes the proposed amendments’ imposition of a quarterly reporting requirement on REPs and NOIEs. While the REP Coalition appreciates the need for the retail market’s participation and assistance in ERCOT’s review and analysis of Demand response products and programs, a four-fold increase in the frequency of reports is unnecessary. The level of Customer participation in those products and programs will not change significantly from quarter to quarter, given the typical term of a contract or agreement is 12 months. Consequently, a quarterly reporting requirement would generate the submission of a substantial amount of redundant data," the REP Coalition said

"Moreover, the cost of submitting the requested information on an annual basis today is not insubstantial. The proposed amendments would, in effect, multiply that cost by four. ERCOT should be mindful of the adverse impact its proposal will have on the continued efforts of REPs and NOIEs to provide Demand response opportunities to their Customers, in terms of both the resources those entities must devote and the costs they must expend to comply with a quarterly reporting requirement," the REP Coalition said

"ERCOT’s proposal requires the issuance of a single annual report no later than November 30th of each year. Rather than unnecessarily increase the frequency of REP and NOIE reporting, the REP Coalition asserts that ERCOT should instead engage in a dialogue with REPs and NOIEs to develop a reporting framework that provides ERCOT the information it needs to meet the proposed November 30th annual report deadline," the REP Coalition said

"We look forward to discussing these comments with ERCOT and the Public Utility Commission of Texas (PUCT) to ensure all viewpoints are considered to achieve the most efficient process in ERCOT’s review and analysis of dynamic pricing and Demand response products and programs," the REP Coalition said

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