AUSTIN, Texas — Acting on a request from Texas Gov. Greg Abbott’s office, ERCOT has drafted a revision to its planning guide requiring energy developers to notify the Department of Defense of any projects near military installations.

The planning guide revision request (PGRR 047) was unanimously approved by ERCOT’s Technical Advisory Committee last week and will be considered by the Board of Directors during its Oct. 11 meeting.

The revision requires developers seeking an interconnection agreement to include among their materials a signed affidavit that they have notified the department of its proposed project and requested its review. The declaration only requires the initiation of an informal review, not its completion.

The proposed change is in response to requests by the governor’s office and the Defense Department to require that any proposed construction covered under existing federal regulations “confirm that they have provided notice and obtained review from the [Federal Aviation Administration] and DOD to the extent required under federal law.”

Current federal regulations require any structure constructed above certain height limits (approximately 200 feet) or in proximity to military and civilian airports provide notice to the FAA and DOD siting clearinghouse.

Several projects have recently brought the issue of federal notification to the forefront.

Sheppard Air Force Base near Wichita Falls has said proposed wind developments nearby would interfere with its radar and flight training operations. A proposed wind farm near Corpus Christi in South Texas has drawn concerns that it could impact training missions at two nearby U.S. Navy airbases, despite FAA’s conclusion to the contrary. (See “FAA Stands by its Greenlight for Proposed Wind Farm,” Federal Briefs.)

Speaking before the Texas House of Representatives’ Defense and Veterans Affairs Committee on Aug. 24 in Wichita Falls, ERCOT Director of System Planning Warren Lasher said he wants to see “increased coordination and communication” between the military and wind energy developers to resolve conflicts. “This will ensure that all energy developers check with DOD well before” the developments are put into motion, he said, according to an account in the Times Record News.

The TAC ensured the proposed rule would only affect developments that are not already connected to the power grid. The committee set Nov. 1, 2016, as the effective date for the change, after staff tracked down Lasher at a Public Utility Commission of Texas meeting for his approval.

Related legislation is expected to be proposed when the Texas Legislature begins its 2017 session in January. A Wichita Falls representative is considering filing a proposal that would affect tax abatements for some wind projects near military bases, while a New Braunfels legislator has said she would intervene if an energy project endangered military missions, the Times Record News reported.

Changes in TAC Leadership

Last week’s meeting marked the end of Randa Stephenson’s tenure as TAC chair. Stephenson, of the Lower Colorado River Authority, was recently named the utility’s vice president of wholesale markets and support.

Stephenson said her new job came with additional responsibilities that would preclude her continued role as TAC chair. She said she was disappointed but would continue to participate through the end of the year.

“Are you really disappointed?” asked ENGIE’s Bob Helton, to peals of laughter.

Stephenson “has been a workhorse for the TAC process for many, many years,” said CPS Energy’s Adrianne Brandt, who was unanimously approved as Stephenson’s replacement. “She’s given us almost five years of TAC leadership. It’s a lot of work and a thankless job.”

Helton was unanimously approved as the TAC’s vice chair, replacing Brandt.

TAC Sends 16 More Change Requests to Board

The committee sent 16 other revision requests to the board, endorsing eight Nodal Protocol revision requests (NPRRs) and eight revisions to the nodal operating guide (NOGRRs), the planning guide and the retail market guide (RMGRRs). All but one of the requests passed unanimously.

In addition, the TAC tasked the Wholesale Market Subcommittee to develop a long-term solution for reliability-must-run mitigated offers after a related rule change failed on appeal last month at the committee and this month before the board (NPRR 784). (See “Board Rejects RMR Mitigated-Offer Appeal, Lets Stakeholder Process Move Forward,” ERCOT Board of Directors Briefs.)

“In our discussions with stakeholders, it seems there’s general support for a long-term solution gravitating around placing RMR offers last in the stack,” said NRG Texas’ Bill Barnes, who has championed the revision request.

The 16 revision requests approved are:

• NPRR 753: Gives non-modeled generators the option of using the advanced metering system data submittal process and requires the installation of ERCOT-polled settlement meters to ensure the energy flows are reflected in real-time initial statements.
• NPRR 760: Ensures that operating days with no activity are captured in the denominator for calculations of credit variables. It received two no votes and three abstentions.
• NPRR 778: Changes competitive retailer rules regarding move-in or move-out date changes to prevent an inadvertent error. The change should eliminate two-thirds of manual interventions currently required.

A companion change, RMGRR 139, modifies market processes to align with NPRR 778’s proposed changes.

• NPRR 779 and PGRR 048: Clarify references to the Texas Reliability Entity and the Independent Market Monitor. Current protocols refer to the Texas RE in both its capacity as the Regional Entity and the Public Utility Commission of Texas Reliability Monitor. The NPRR also removes the 24-hour deadline for ERCOT to notify the Reliability Monitor of a failure to provide ancillary services. The new language clarifies that the IMM is an included party in several provisions related to the ERCOT stakeholder process.
• NPRR 782: Removes inconsistencies in protocol language by changing the equations governing the settlement of ancillary services. The change affects resources unable to deliver on their ancillary services obligations because of transmission constraints.
• NPRR 785: Allows ERCOT to automatically prepopulate current operating plans (COPs) for wind and photovoltaic resources with the most recent forecast for the next 168 hours. Qualified scheduling entities representing these resources can either submit the prepopulated forecast as the COP by default or submit a lower number.
• NPRR 786: Corrects the allocation of transmission losses, distribution losses and unaccounted-for energy (UFE) so that negative loads do not result in loss of UFE allocations.
• NPRR 787: Removes the requirement that the qualified scheduling entity receiving a verbal dispatch instruction confirmation include the name of the individual that received the confirmation within the electronic acknowledgement.
• NOGRR 150: Moves voltage-support obligation language to the Operating Guide so that the requirements are recognized as binding. It also allocates voltage-support responsibility to the appropriate entity, and clarifies that the ERCOT transmission operator has the authority to instruct a QSE to modify its resource’s voltage set point.
• NOGRR 158: Modifies language in the nodal operating guide relating to limits on hydro resources’ responsive reserve to ensure consistency with NPRR 669.
• PGRR 049: Removes the option to submit generation interconnection or change request (GINR) applications through standard mail or fax and updates the mailing address for GINR payments to the ERCOT treasury department.
• RMGRR 134: Gives non-modeled generators the option to use the advanced metering system data-submittal process and clarifies processes for unregistered distributed generation versus registered non-modeled generators.
• RMGRR 140: Removes the current date restrictions to give ERCOT increased flexibility when executing a competitive retailer’s acquisition of another retailer’s customers to prevent a “mass transition event.” The change will prevent end-use customers from being transitioned to provider-of-last-resort service and reduces associated uplift to the market.
• RMGRR 141: Clarifies procedures during an extended unplanned system outage.

– Tom Kleckner