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Texas PUC Staff Considering As-Needed Service, Or Seasonal Service, Among Options To Implement Large Load Demand Reduction Reliability Service
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Staff of the Texas PUC have sought comment on two options, an as-needed service or a seasonal service, which Staff is considering to implement a legislative mandate for the creation of a reliability service to procure demand reductions from large load customers
PURA § 39.170(b) directs the PUC to require ERCOT to develop a reliability service to competitively procure demand reductions from large load customers with a demand of at least 75 megawatts (MW) to be deployed in the event of an anticipated emergency condition.
Under statute, the rules developed to govern such service must:
(1) specify the periods when the service may be used to assist with maintaining reliability during extreme weather events;
(2) ensure that ERCOT provides at least a 24-hour notice to large load customers and requires each large load to remain curtailed for the duration of the energy emergency alert event or until the load can be recalled safely; and
(3) prohibit participation by any large load customer that curtails in response to the wholesale price of electricity, as determined by ERCOT, or that otherwise participates in a different reliability or ancillary service.
Staff said that an "As-Needed" option to implement the new law would procure the demand reductions on an as needed basis just prior to an extreme event identified by ERCOT. Only offers that have met pre-qualified requirements would be considered during the procurement process.
The As-Needed procurement would be initiated via a market notice, and would procure all available offers up to, but not to exceed, a specified spend limit from the pre-qualified list of resources.
The Seasonal option would be procured on a seasonal basis prior to the start of each defined season, to be available as an additional tool during any event during the season as needed by the ERCOT operator. Any interested resource would need to complete the qualification requirements in compliance with the seasonal procurement schedule provided by ERCOT. This process would be similar to the current procurement process for ERS, Staff said
For both options, the instruction to deploy service must be at least 24 hours in advance of the beginning of the sustained response period (to fully deploy and meet obligation).
For both options, participating loads must be represented by a QSE
Staff asked stakeholders, of the two options presented (an as-needed service or a seasonal service), which is the better option to implement PURA § 39.170(b), and why?
Among other things, Staff asked whether PURA authorizes ERCOT to deploy the new service in circumstances other than extreme weather events? If yes, what kind of events?
Staff also asked whether the Commission should define "extreme weather event", and, if so, how should it be defined?
Staff asked what specific prohibitions, if any, not enumerated in PURA § 39.170(b) [prohibitions noted above] should apply to participation in the new service?
Specifically, in implementing the prohibition on eligible loads also engaging in price responsiveness to wholesale prices, Staff asked whether participation in price responsiveness to transmission scarcity such as four coincident peak (4CP), or a successor methodology, should preclude participation in the new large load DR service
Staff asked whether the Commission should define the language "curtailment in response to wholesale price of electricity" and, if so, how should it be defined?
Staff's complete list of questions and slides with further details on the two proposals can be found in Staff's March 23, 2026 filing in Project 58482
Project 58482
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March 23, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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