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PRS 11/17/21

Table of Contents

Executive Summary

NPRR1107 (fees for weatherization inspection) and NPRR1109 (allowing recently retired resources to get back onto system without full interconnection process) were the only items up for discussion this PRS and they both passed. NPRR1107 did get significantly changed, however, as it is now a fee that will be assessed to all ERCOT generation resources on a nameplate MW basis, rather than a per inspection fee.  As the only resources that were to be inspected were those that failed during Uri, this is a win for poorly weatherized generators.  1109 passed without modification, though some participants were unhappy with the implied softening of retirement implications and the fear that resources might now choose retirement over mothballing.  



  • NPRR1107(fees for weatherization inspections) passed (90% in favor, 10% opposed) in a heavily modified version.  Whereas the original version had a $12,500 fee for dispatchable resources (and $4,000 for intermittents, storage, and distributed resources) that had failed in Uri and were subsequently inspected, the version that passed spreads the cost out across all resources based on nameplate rating.  This is a significant redistribution of cost from 1) resources that failed in Uri to all resources, and 2) dispatchable, expensive to inspect resources to intermittent, cheap to inspect resources.  At the very end, ERCOT did express concerns about the commented language and it may be revisited at TAC.  Also, Eric Goff committed to write language that would institute a true up charge if the inspection charges went over the charged fees, such that ERCOT’s general fund isn’t impacted.
  • NPRR1109(allowing recently retired resources to get back onto system without full interconnection process) passed (70% in favor, 30% opposed) in its original version.  There was some concern that this was a major rewrite the significantly changed the meaning of “retirement” in ERCOT, and that if the PUC wanted specific resources to return to the market for this winter, they should make “good cause exceptions” for those resources at the commission, rather than change the meaning of retirement.  However, at the end of the day, the NPRR passed, likely because the commission clearly wanted it to pass.  As an aside, Ian Haley from Luminant said that an ERCOT staffer had called him up and told him which resource this NPRR was written for (apparently a 59MW resource that had been owned by Luminant until recently).  I am not particularly excited about ERCOT staff volunteering material future resource information to market participants with significant CRR portfolios and was surprised to hear that this had happened.  It will be interesting to see if that has any ramifications for ERCOT staff.


Discussed Issues

  • NPRR1107 (Weatherization Inspection Fees)
  • NPRR1109 (Un-retiring resources without studies)