NPRR 336, Authorize ERCOT to Procure Additional RRS During Severe Cold Weather Consideration of Tenaska and Luminant Comments

Original NPRR 336 Defined Cold Weather Watch and Severe Cold Weather Watch ERCOT directed to purchase additional 1150 MW RRS from Generation Resources for either condition Startup all Generation Resources which have startup times greater than one hour

Tenaska Comments Deleted the specification that the additional RRS be procured from Generation Resources

Luminant Comments Changed additional RRS procurement to NSRS and gave ERCOT discretion as to quantity Introduced a new defined term, Conditional Reliability Unit Commitment Conditional Reliability Unit Commitment A RUC instruction which is issued by ERCOT prior to the Day Ahead Market for an Operating Day due to the forecasted loads requiring a Resource with longer than 10 hour start time. A Resource that receives a Conditional Reliability Unit Commitment prior to the DAM for an Operating Day will be eligible to participate in the DAM or self commit prior to the DRUC process for the Operating Day and if not otherwise committed, will receive a RUC instruction with no clawback provisions.

Possible Cold Weather Scenario ERCOT knows at 07:00 on Day 1 that they want a Unit online and available for morning peak of Day 2, HE06. They do not want to wait until after DAM to begin the startup. Issue a Conditional RUC The Resource may participate in DAM If its TPO is struck, it must DAM Commit If TPO not awarded, it has CRUC status for next day COP. CRUC status settled with RUC make whole and no clawback. If not in DAM, use VC or Generic Cap for startup and min energy costs.

Possible Settlement Implications If not DAM committed, the Resource shows CRUC status in COP so that additional capacity not DRUC committed. Concern: Could this give advantage to longer lead time Resources due to elimination of clawback? Question: Is it important for ERCOT to be able to issue a RUC before 16:00 Day Ahead? If not, this provision is not needed.

QMWG Recommendations Tenaska comments regarding Load Resources? Luminant comments regarding NSRS instead of RRS? Discretionary amount of NSRS? Concept of early RUC?