Texas PUC Staff Posts Strawman Draft Rule On Transfer Of Load In/Out Of ERCOT

June 9, 2020

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Copyright 2010-20 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Staff of the Public Utility Commission of Texas have filed a strawman draft rule relating to the transfer of load into or out of the Electric Reliability Council of Texas (ERCOT) power region.

Proposed Subst. R. 25.226 would govern permanent load transfers as well as block load transfers (as defined in the ERCOT Nodal Protocols)

Under the strawman, a utility must obtain commission approval before making a permanent load transfer.

Among other things, the strawman provides that an application filed at the PUC for a permanent load transfer shall include:

• a description of the costs and benefits of the transfer for the affected entities, including monetary estimates

• the demand values for the affected load that coincide with the demand intervals most recently used by the commission in the determination of monthly transmission service charges under §25.192 (relating to Transmission Service Rates);

• a description of any expected adverse effects of the transfer, both before the transfer date and during the ten years beginning on the transfer date, and a detailed plan for addressing those effects

• the measures that will be taken to ensure that no entity or individual involved with the load transfer will take any direct or indirect action that would cause ERCOT or a market participant within the ERCOT power region that is not a public utility under the Federal Power Act to become a public utility under the Act or otherwise become subject to the plenary jurisdiction of the Federal Energy Regulatory Commission, and the measures that will be taken to ensure that no commingling of energy between ERCOT and the other power region that the affected load is being disconnected from or interconnected to occurs before the transfer date, during the physical disconnection and interconnection of the affected load to or from ERCOT and to or from the other power region, and at all times thereafter

• production-cost analyses of the transfer paid for by the utility and conducted by ERCOT and any RTO of which the utility is a member or will become a member after the transfer. The utility may provide an explanation of why such analyses are unnecessary.

The strawman provides that, if the commission approves the transfer, ERCOT has the discretion to postpone the transfer date if it determines the transfer will be a risk to the reliability or adequacy of the ERCOT power region system because of the expected conditions of the system on the transfer date

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