Texas Staff Outline Potential Next Steps in Consideration of Potential Changes To ERS

Staff of the Public Utility Commission of Texas have outlined three potential options for the next steps in the Commission's consideration of potential changes to Emergency Response Service (ERS)

Among the changes on which stakeholder input had been sought was daily procurement of ERS on the day prior to the operating day

Staff's memo summarized stakeholder comments, noting the disparate policy preferences expressed by interested parties

Click here for a review of some of the stakeholders comments, including proposals to eliminate ERS, and proposals to integrate ERS into SCED

Citing the disparate stakeholder views, Staff proposed the following options for Commission consideration:

Option One:

a) Conduct a workshop, possibly with Commissioner participation, to clarify the parties’ positions and obtain additional information before proceeding with this project.

b) Direct Staff to draft a strawman rule that would require procurement of ERS on a daily basis. In the alternative, Staff could draft a strawman that generally retains the current program design but implements relatively minor changes that may improve the efficiency of procurement.

Staff noted that changes to the current program suggested by some commenters could be effected without revisions to the rule. Allowing ERS participants to adjust their offers during the contract period, establishing a MW capacity requirement (so long as the annual cost cap is not exceeded), or adjusting the length of the contract term (including establishment of a one-day contract period), are all within ERCOT’s discretion under the current rule. The Commission could endorse one or more of these proposed changes, and direct ERCOT to proceed through the stakeholder process to implement the changes. Other proposed changes, such as increasing or eliminating the annual cost cap specified in P.U.C. Subst. R. §25.507(b), or making ERS available for deployment to avoid local load curtailment, would require a rulemaking to implement.

Option Two:

The Commission could direct ERCOT to conduct a pilot program under P.U.C. Subst. R. §25.361(k) to evaluate daily procurement of ERS and report on the results of the trial to further inform this rulemaking. Once ERCOT has completed such a pilot and has provided a report on its findings, the Commission could then direct Staff to proceed with Options One or Three.

Option Three:

Take no action at this time in light of the concerns raised by current ERS participants and in light of the fact that development of the Multi-Interval Real Time Market (MIRTM) and Loads in SCED v. 2.0, which are being evaluated in the ERCOT stakeholder process, may provide significant opportunities for loads and aggregations of loads to participate in the real-time market.

Project 45927