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Texas PUC Staff Propose Guidance That DRRS Under NPRR 1309 Should Be Developed Without Attempting To Include Energy Storage Resources, To Avoid Delay
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Staff of the Texas PUC have requested that the Commission provide guidance to ERCOT market participants regarding the circumstances under which energy storage resources (ESRs) may participate in Dispatchable Reliability Reserve Service (DRRS).
Staff recommended that the Commission consider providing the following guidance to stakeholders regarding ESR participation in DRRS:
1. Stakeholders should continue to develop DRRS without attempting to include ESRs to avoid delaying the implementation of the core DRRS functionality in NPRR 1309.
2. ESR participation in DRRS should be considered independently of both NPRR 1309 and NPRR 1310.
3. To the extent ESR participation is permitted in DRRS, it should be limited to resources with sufficient storage capacity (MWh) to discharge at their maximum sustained discharging capability (MW) for at least four hours (e.g., four-hour ESRs).
4. The requirements of PURA § 39.159(d)(2)(A) and (B) should be considered a joint requirement. Specifically, a resource qualifies to provide off-line DRRS up to the power output (MW) it can reach within two hours of being called on for deployment.
5. The duration requirement for DRRS should be kept at four hours for now and not increased yet as allowed by statute.
In support of its proposals for PUC consideration, Staff said, "As an initial matter, PURA § 39.159(d) requires the development of an ancillary service program focused on the ability of dispatchable generation resources to provide electricity for at least four hours within two hours’ notice. The inclusion of other types of dispatchable resources -- such as ESRs -- is not a core requirement of DRRS in the statute. As a result, Staff recommends that ESR participation in DRRS should not be incorporated into the core functionality reflected in NPRR 1309. This permits stakeholders and ERCOT to focus on finalizing development of the core service rather than focusing on the unique details related to ESR participation."
Staff further said, "Additionally, Staff recommends that ESR participation be considered in a separate revision request independent of NPRR 1310, which primarily focuses on developing optionality of DRRS as a resource adequacy tool. Because ESR participation is distinct from the resource adequacy aspects of NPRR 1310, this issue would benefit from being considered separately."
Staff further said, "Staff recommends that compliance with PURA § 39.159(d)(2)(A) for ESRs be based on physical discharge capability (in MWs) without regard to instantaneous state of charge (in MWhs). PURA § 39.159(d)(2)(A) requires eligible resources to be 'capable of running for at least four hours at the resource’s high sustained limit.' Because this provision requires 'running . . .at the resource’s high sustained limit' for four hours rather than merely 'running' for four hours, the law indicates an expectation of maximum capability for four hours as opposed to four hours’ worth of capability."
Staff further said, "Furthermore, PURA § 39.159(d)(2)(C) requires 'the dispatchable flexibility to address inter-hour operational challenges.' The use of the phrase 'inter-hour', as opposed to 'intra-hour', combined with the expectation that a resource 'run' for four hours suggests that the provision of DRRS by one-hour duration resources was not anticipated. While it is technically feasible for ESRs to limit their discharge rate to last longer, this would only create the appearance of a longer duration. A resource that can be rationed over four hours is not the same as a resource that actually possesses a four-hour duration. Rather than lower the qualifications to support existing resources, the Commission should allow the market to function. The competitive market structure will determine whether the statutorily required DRRS qualifications are best met by ESRs with longer durations or some other technology."
"Staff recommends that PURA § 39.159(d)(2)(A) and (B) be considered a joint requirement, meaning that the quantity of off-line DRRS that a resource can provide is the MW quantity of power that it can provide within two hours. Under PURA § 39.159(d)(2)(B) a DRRS-eligible resource must 'be online and dispatchable not more than two hours after being called on for deployment.' The concept of a resource being eligible to provide DRRS by being able to come online within two hours is distinct from the quantity of DRRS that a resource is eligible to provide from its off-line status. However, given the two-hour deployment requirement, it is logical to quantify the provision of off-line DRRS as the amount of capacity that can be provided in two hours. Once the resource is online, it can offer to provide amounts of on-line DRRS consistent with its new status," Staff said
Staff said, "Pursuant to PURA § 39.159(e), ERCOT 'may require a resource to be capable of running for more than four hours as the organization determines is needed.' At this time, there is insufficient basis to increase the DRRS duration requirement beyond four hours. However, Staff anticipates that adjustments would be considered as part of the annual review of ancillary services."
Project 55797
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Staff Makes Recommendations On Energy Storage Resource Eligibility, Hours
March 19, 2026
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Reporting by Paul Ring • ring@energychoicematters.com
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