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Texas Consumer Group Petitions PUC To Develop Cost Impact Information For ERCOT Market Reforms, Other Actions

February 23, 2022

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Copyright 2010-21
Reporting by Paul Ring •

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Texas Consumer Association and Alison Silverstein, an energy consultant, petitioned the Texas PUC to direct ERCOT to produce electricity cost impact information in Project No. 52373, the Review of Wholesale Electric Market Design

The petitioners said, "In the interests of public transparency and accountability, we respectfully request that the Commission immediately direct ERCOT to compile, report and explain the costs of all reliability measures implemented to date, and to provide monthly updates and data files for these costs going forward."

The petitioners said that such reports should include at minimum the following reliability cost components:

• PUCT-initiated reliability changes to date

-- Changes due to price cap revisions

-- Changes due to ORDC revision

-- Any other PUCT reliability initiatives that have caused electricity price increases

• ERCOT-initiated reliability changes

-- Increased Reliability Unit Commitments (detailing amounts netted out between power marketers, whether and how netting affects RUC availability and total costs, and how much of RUC costs have been uplifted to all ERCOT load)

-- Increased procurement of Regulation Service

-- Increased procurement of Responsive Reserve Service (spinning reserve)

-- Increased procurement of Non-Spinning Reserve Service

-- Changed procurement of Emergency Reserve Service

-- Impacts of these changes upon ERCOT congestion revenues

• PUCT-approved and/or pending Uri loss securitization charges from the implementation of Utilities Code Chapter 39, that will be uplifted to wholesale market participants pursuant to Subchapter M and retail customers that are not opted-out pursuant to Subchapter M.

• Any Railroad Commission-approved and/or pending Uri loss securitization charges that are passed through in power plant gas delivery and energy charges.

• Identification and details on any other electricity-affecting cost components that have materially changed due to reliability-driven policy or operational decisions made by ERCOT or the PUCT since February 2021.

Petitioners asked that the above data be provided with the further details itemized below:

• "Data requested -- a CSV file showing for each ancillary service the cost paid, hours called, total ancillary service capacity availability, and total volumes procured per service and total ERCOT market-wide electricity costs by hour and day since January 1, 2020, with monthly and weekly totals for each service and the ERCOT market as a whole. This will enable analysts to identify cost impacts due to changes in price and procurement volumes over time."

• "A clear explanation for the public of how the changes in energy price cap and ORDC calculation affect ancillary service prices and availability and ERCOT congestion costs."

• "ERCOT’s determination of the need for conservative operations is affected in part by the accuracy of its advance assessments of thermal plant availability, wind and solar generation, and customer loads relative to actual generation and loads. Therefore, we request that ERCOT provide these data along with a detailed analysis of the patterns and magnitudes of ERCOT’s generation forecasts (both plant availability and production) and load forecast accuracy and errors under both routine and grid stress conditions, so the Commission and stakeholders can understand the likely impacts of ERCOT’s forecast errors on operational reliability and costs."

Project 52373

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