PRS 2/16/22 - CIMView

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PRS 2/16/22

Table of Contents

Executive Summary

This special PRS was entirely focused on two NPRRs, NPRR1097(ERCOT forced outage report) and NPRR1120(Firm Fuel Supply Service).  

The NPRR1097 discussion dealt with  whether the Resource Entity should be in the report (resolution = no) and what language to use to allow state governmental entities to see outage data right away during an EEA (“State Governmental Authority”).

The NPRR1120 discussion was much longer (about 2.5 hours) and was mostly various companies running through their comments with ERCOT giving a thumbs up or down on the comments as they were stated.  The various proposals and ERCOT’s verdict are detailed below.  Also, ERCOT stated 1) that it was not yet decided whether this was “pay as bid” or clearing price, and 2) they were going to try their best to get the RFP out by the end of March.



  • NPRR1097(Forced Outage Report)- The two remaining issues on this NPRR were 1) who gets to see the outage information instantly in a EEA situation and 2) whether the Resource Entity name is included in the report (the resource name *is* included in the report, Resource Entity is a separate designation).  After much debate, “a State Governmental Authority” was added and the Resource Entity name was removed then the Joint Commenters comments with desktop edits was passed.
  • NPRR1120(Firm Fuel Supply Service)
    • Between last week’s PRS meeting and this PRS meeting, ERCOT, Steel Mills, STEC, Luminant, CPS, and ERCOT again filed comments on this NPRR.
    • ERCOT stated that their goal is to get a draft RFP in front of market participants by the end of March.
    • ERCOT 2/11/22 comments 
      • Shorten the planned outage restriction window to Dec 1 to March 1.
      • Clarify that FFSS deployment is via VDI
      • Let QSEs request fuel oil restocking (instead of only ERCOT can initiate)
      • Change minimum availability from 95% to 90%
      • Add a penalty for FFSS resources that aren’t available during winter weather watch.
    • Steel Mills (Floyd Trefny) 2/12/22 comments
      • ERCOT should manage FFSS burn rate via LSL direction
      • ERCOT should warn FFSS resources hours in advance (ERCOT 2/15/22 accepted)
      • Availability requirements should be higher and only measured when there is a winter weather advisory.
      • ERCOT should recognize that fuel oin restocking is variable from plant to plant.
      • ERCOT should start with “pay as bid” and only move to “clearing price” after a few years.
    • STEC 2/14/22 comments
      • Don’t use FFSS until you have to. (ERCOT 2/15/22 accepted)
      • Don’t deploy FFSS resource in violation of its environmental permitting (ERCOT 2/15/22 accepted)
      • Clarify when an FFSS VDI deployment should end (ERCOT 2/15/22 accepted)
      • Don’t clawback profits after the FFSS contract hours have been met. (ERCOT 2/15/22 accepted -in concept, language adjusted)
      • Clarify 5% deadbands in qualification/testing/decertification section.(ERCOT 2/15/22 clarified)
    • Luminant 2/14/22 comments (filed on top of STEC’s 2/14/22 comments)
      • Clarify that FFSS is a product to ensure resource availability (ERCOT 2/15/22 accepted)
      • Clarify that an FFSS resource is only considered an FFSS resource during the Nov 15 – Mar 15 award obligation period (ERCOT 2/15/22 accepted)
      • Make the cost recovery process easier(attestation/filing deadline/input-output documentation)(ERCOT 2/15/22 rejected)
      • Resources don’t have to test if they were successfully deployed (via FFSS) for more than 60 minutes that year.(ERCOT 2/15/22 accepted)
    • CPS 2/15/22 comments
      • There should be a self-arrangement mechanism for gen/load entities. 
      • Clearing price would allow self arrangement more easily, and is thus superior.
      • ERCOT should develop clear guidelines for when to deploy FFSS 
      • ERCOT should report back to the board every time FFSS is used. (ERCOT 2/15/22 accepted)
    • ERCOT 2/15/22 comments – acceptance and rejection of above comments as noted with additional clarifications of possibly vague language.

Discussed Issues