Texas PUC Staff Make Recommendations On Reliability Standard, Addressing Mandate, Deliverability, Seasonality, Locationality, More
April 20, 2023 Email This Story Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • email@example.com
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Staff of the Texas PUC have issued a memo with recommendations concerning establishment of reliability standard for the ERCOT market
Staff's memo outlined questions before the PUC as well as stakeholder comment
In terms of recommendations, Staff said, "Staff agrees with commenters and supports the consideration of several reliability metrics and a reliability standard that will measure multiple metrics."
"Staff believes that the ERCOT duration/frequency/magnitude framework will achieve this objective," Staff said
"Staff reserves judgment on the specific reliability standard pending further policy review, but Staff agrees that thorough analysis is required before moving away from the traditional industry standard of 0.1 LOLE. Deviation from the industry standard, particularly to a lower threshold for the reliability standard, needs to have a reasoned justification," Staff said
Staff said, "For the Commission’s previously adopted Performance Credit Mechanism to be effective, Staff believes that the reliability standard must be a mandated requirement once the final market design goes live."
"Staff also agrees that cost considerations are important and need to be taken into account. Accordingly, it recommends the Commission direct ERCOT to include the anticipated cost of meeting the various reliability standards and provide sensitivity analysis," Staff said
Concerning deliverability, Staff said, "Staff acknowledges the importance of deliverability in ensuring reliability across the ERCOT power region but agrees with ERCOT that deliverability should be addressed outside of establishing the reliability standard."
"Staff recommends that the Commission direct ERCOT to conduct a full deliverability study once the final market design is implemented," Staff said
"Staff agrees with comments that embedding a locational requirement or seasonal component within the reliability standard is not needed at this time, as these should be captured within a robust region-wide, annual reliability standard," Staff said
"The complexity of these additions would also likely delay the initial implementation of a reliability standard. If a specific need is identified, the locational and seasonal requirements can be thoroughly studied in a future project," Staff said
"Staff also agrees with comments that view capturing extreme events as one of the critical components to consider when developing a reliability standard for the ERCOT power region. Staff recommends that the Commission support reviewing reliability metrics in a risk-averse manner, including giving ERCOT direction to review the CVaR proposal suggested in several comments," Staff said
"Staff agrees that distributed energy resources and load resources should be considered within the reliability standard analysis. ERCOT and stakeholders should continue to work to identify any improvements that are needed to consider these resources more accurately within the model," Staff said
In terms of updating the reliability standard once established, Staff recommends establishing an initial schedule where the requirement necessary to meet the defined reliability standard is calculated annually.
"This will provide up-to-date information to the Commission and ERCOT to assess whether the region is meeting the set reliability standard and to take any interim steps necessary until the long-term market design is fully implemented. Once the final market design is implemented, the timeline for refreshing the requirement should align with the cycle of the implemented market design," Staff said
"Lastly, Staff agrees that the Commission and ERCOT should consider potential legislation when reviewing the reliability standard framework. Staff recommends that pending legislation that could impact the market design and reliability standard should be modeled as a sensitivity, with legislation that is ultimately approved being fully included in the base model," Staff said