Texas Generator, PUCT Staff Seek Approval Of Voluntary Mitigation Plan
August 19, 2019 Email This Story Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
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Luminant Energy Company LLC and Staff of the Public Utility Commission of Texas have filed for approval of a Voluntary Mitigation Plan (VMP) which would, pursuant to PURA § 15.023(f) and 16 Tex. Admin. Code § 25.504(e), specify offering practices that Luminant can use when
offering its generation resources into the Electric Reliability Council of Texas real-time energy
market during the term of the agreement and specify that those offering practices will not be considered an
abuse of market power.
Under the proposed agreement, adherence to this VMP, while it remains effective, shall provide Luminant with an
absolute defense against allegations of abuse of market power through economic
withholding with respect to the specific behaviors addressed by the VMP
The VMP addresses Luminant's offer strategy for six different technology types:
nuclear, solid-fuel (coal and lignite), non-quick start natural gas, quick start natural
gas, intermittent renewable resources (wind and solar), and batteries. With respect to nuclear, coal, and natural gas fired units, the VMP will only apply to
units in Luminant's fleet at the time of approval of the VMP.
Apart from provisions allowing parties to terminate the VMP earlier, the VMP
shall automatically terminate without any further action by a Party upon the earlier
of: (a) ERCOT's go-live date for Real Time Co-optimization; or, (b) The day that is seven years from the date the Commission approves this
VMP; or, (c) The day Luminant's Installed Generation Capacity, as that term is defined
in 16 Tex. Admin. Code § 25.5, drops below 5% of the total ERCOT
Installed Generation Capacity in the most recent Estimate of Installed
Generation Capacity in ERCOT Memorandum filed in Project No. 39870,
or its successor project.
The VMP provides that:
• Day-Ahead Market (DAM) Offers and Bids: Offers and/or bids for energy and ancillary
services in the DAM can be made at prices up to and including HCAP.
• Loads in SCED: Bids for energy may be submitted at any price, subject to any load bid
caps set by the PUC.
• Nuclear Units: Energy Offer Curves (EOCs) for the Comanche Peak units shall be
submitted into the real-time market with values no higher than $10/MWh.
• Non-Spinning Reserve Service: Any MWs from On-Line and Off-Line NSRS shall be
offered at prices no higher than $250/MWh, unless required by an applicable ERCOT
Protocol. This section does not apply to offers pursuant to a separate VMP provision governing Quick Start CTs
• Intermittent Renewable Resources (IRRs): Any MWhs from IRRS [sic] (including wind and
solar) shall be offered at no higher than $10.00/MWh.
• Batteries: Energy Offer Curve (EOCs) from each unit shall be no greater than the higher of (1) the price point
on the ERCOT Power Balance Penalty Curve associated with capacity equal to the
Summer Rating HSL of each unit or (2) five (5) times the highest hourly DAM price for
the Resource Node for the operating day.
• The VMP also governs offers from Lignite and Coal Units, Non-Quick Start Operated and Non-Combined Cycle Natural Gas Units; Combined Cycles, and Quick Start CTs, as described in detail in the VMP which can be seen here