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Firm Fuel Supply Service

Table of Contents

The Gist

As part of phase 1 of the PUC’s market redesign efforts, ERCOT was directed to implement a firm fuel service, as imagined in Senate Bill 3.  It would be paid to gas generators that have onsite fuel storage to run for at least 48 hours.  This will be implemented in two phases; the first phase for winter 22/23 will be an RFP process that is (most likely) only for oil storage for dual fuel plants; the price could be determined on a “pay as bid” process or via a single clearing price.  (Pay as bid would be simpler to implement, but has some significant fairness issues, as entities with load and generation could supply their share of FFSS but still end up paying for FFSS if their costs were lower than others costs).  The second phase 23/24 and beyond will possibly include more technologies and a slicker auction process.

Important Actions

  • 12/6/21 PUC includes Firm Fuel Service in the market redesign blueprint 
  • 1/10/22 ERCOT states in its initial implementation timeline that it will take 12-24 months to implement the Firm Fuel Service program.
  • 1/13/22 PUC expresses dismay that FFS will take 12-24 months to complete, they would like it to be inplace for next winter; ERCOT says that to meet that timeline the Firm Fuel Service will have to be an RFP process. 
  • 1/26/22 McAdams and Cobos file memos detailing what they think FFS should look like
  • 1/27/22 McAdams removes Day Ahead offer requirement from his vision; Cobos removes quarterly invoicing from her requirements.  ERCOT to come back to future meeting with details on how this is implemented in other ISOs.
  • 1/31/22 ERCOT files NPRR1120
  • 2/4/22 Survey results due (on how much potential Firm Fuel Storage exists in ERCOT already)
  • 2/9/22 Firm Fuel Workshop at ERCOT
  • 2/11/22 ERCOT files comments including agreed upon concepts from 2/9/22 workshop.
  • 2/12/22 Steel Mills file comments
  • 2/14/22 STEC files comments
  • 2/14/22 Luminant files comments
  • 2/15/22 CPS files comments
  • 2/15/22 ERCOT files comments (clarifications and agreed upon concepts from Steel Mills/STEC/Luminant/CPS comments)
  • 2/18/22 ERCOT files comments
  • 2/23/22 TAC approves LCRA Comments (which include ERCOT and STEC and Demand Control2 comments)


Senate Bill 3 (enrolled version text)

Phase 1 and 2 Market Reform Blueprint

McAdams and Cobos memos 

Firm Fuel Service NPRR (NPRR1120)

Meeting Notes

3/10/22 PUC

2/25/22 PUC

2/23/22 TAC

2/16/22 PRS

2/9/22 PRS

2/2/22 WMS

1/31/22 TAC

1/27/22 PUC Open Meeting

1/13/22 PUC Open Meeting


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