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Texas PUC Staff Propose To Allow Some Load, Distribution Generation Resources To Provide Generation Firming Requirements
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In a recommended proposal for adoption, Texas PUC Staff recommended that certain load and distribution resources should be designated as eligible resources to meet the firming requirements for generation
As previously reported, Octopus Energy had urged the PUC to allow demand response and DERs to serve as eligible resources to meet firming obligations, including allowing the use of output from an aggregated distributed energy resource (ADER)
Staff recommends, as proposed by industrial customers, that load resources shall be eligible to satisfy the performance requirements of electric generating facilities that are subject to the performance requirements
Staff also agrees that qualifying distribution generation resources (DGRs) and distribution energy storage resources (DESRs) should be eligible to provide firming service
Staff said that DGRs and DESRs are dispatched by SCED, and thus ERCOT has telemetry from these resources.
Staff would decline at this time to include ADERs as eligible to provide firming service.
Staff would also not include settlement only distribution generators (SODGs) as eligible to provide firming service, stating that validation of the performance of these resources would be difficult or infeasible
Under Staff's draft, the following resource types would be eligible to provide firming service:
(A) another electric generation facility;
(B) an energy storage resource;
(C) a distribution generation resource that is registered with ERCOT;
(D) a distribution energy storage resource that is registered with ERCOT; or
(E) a load resource.
Project 58198
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December 4, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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