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ERCOT Recommends Allowing Non-LSE QSEs To Participate In Aggregated Distributed Energy Resource (ADER) Pilot Under New Model, Also Expanding Pilot Caps
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ERCOT has filed at the Texas PUC recommended changes to the Aggregated Distributed Energy Resource (ADER) Pilot program, including a model under which a non-LSE may participate as an aggregator. ERCOT will also undertake an immediate expansion of the program caps
ERCOT will present recommendations to the ERCOT board next week
ERCOT proposes to:
• Allow the additional option to participate as an ADER using the non-Controllable Load Resource (NCLR) participation model. This allows aggregations of sites that cannot incrementally follow SCED basepoints to be eligible to provide Ancillary Services including ERCOT Contingency Reserve Service (ECRS) and Non-Spinning Reserve (Non-Spin), ERCOT said
• Make clarifications related to the process of reviewing Details of the Aggregation (DOTA) submissions and participation in ERCOT’s Emergency Response Service (ERS) program or Transmission and Distribution Utility (TDU) Commercial & Residential Load Management Programs;
• Increase the capacity limits to 160 MW for energy and 80 MW for Non-Spin and ECRS, respectively;
• Expand ERCOT’s discretion for increasing participation limits for the Pilot Project without going through the full Governing Document approval process; and
• Make updates and clarifications to the processes for Premise-level validations.
Regarding the expansion to 160 MW for energy and 80 MW for Non-Spin, ERCOT said, "ERCOT is exercising its discretion to effective immediately move to those limits in advance of Phase 3 approval to accommodate growing interest and recognizing feedback from pilot participants that the current limits are impacting participation and customer engagement in the short-term."
ERCOT said that its proposed Phase 3 of ADER, "will allow a new participation model more akin to Non-Controllable Load Resource (NCLR) participation in the market."
"It [Phase 3] will also enable third-party QSE aggregation from >100 kW premises for ADERs under the NCLR model, regardless of Load Serving Entity (LSE) affiliation, incrementally improving market access," ERCOT said
Under the NCLR, aggregations of devices/premises will be allowed to participate as Aggregate Non-Controllable Load Resources (A-NCLRs).
Such aggregations will be registered and modeled like other ADERs, but using NCLR categories for Resource parameters in ERCOT’s Resource Integration an Ongoing Operations (RIOO) system.
Real-time 2-second telemetry will still be required from the QSE to ERCOT using all NCLR attributes.
These ADERs will be dispatched by the Ancillary Service Deployment Manager like other NCLRs -- No Energy Bids or dispatch through Security-Constrained Economic Dispatch (SCED) in Real-Time.
"NCLR model will allow third-party QSEs to aggregate >100 kW premises, even if the LSE is represented by a different QSE," ERCOT said
ERCOT proposed to require an LSE Acknowledgement [sic] Form to confirm coordination between entities and to avoid cross-settlement processes.
ERCOT would also verify QSE-LSE relationships during its review
As of May 2025, 3 ADERs are qualified, with a total of 15.5 MW capability for energy, 8.6
MW for Non-Spin Reserve Service (Non-Spin), and 8.8 MW for ERCOT Contingency
Reserve Service (ECRS).
Nine additional ADERs are in various stages of registration.
PUC Project 53911
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June 20, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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