ERCOT Stakeholders Wait on Bylaw Amendment Changes

TAC Approves Annual Review

Caitlin Smith, Jupiter Power, during a recent panel discussion. | © RTO Insider LLC

Nov 1, 2022 | Tom Kleckner

ERCOT stakeholders have submitted comments to proposed bylaw changes that have been sitting with the Board of Directors since September.

ERCOT stakeholders have submitted comments on proposed amendments to the grid operator’s bylaws that have been sitting with the Board of Directors since September.

The amendments, drafted by staff at the board’s direction, would no longer require members’ approval of such changes. It would require that members be provided notice and the chance to comment on any proposed amendments or other “fundamental actions.”

Members had until Sept. 30 to comment on the revisions. The board was to discuss the amendments during its October meeting but did not do so in a public forum.

Jupiter Power’s Caitlin Smith filed comments on behalf of 26 other members, saying it is “imperative to emphasize the chilling effect the proposed amendments could have on decisions to enhance and maintain the health and reliability of the ERCOT grid, including continued investment in generation.”

“A successful energy-only market requires that its participants have a vested interest in the activities of the organization,” Smith said, referring to the development and refinement of market policy and rules.

“Corporate members must vote to amend the ERCOT bylaws,” she said. “Eliminating this right of ERCOT stakeholders is a clear signal to investors of regulatory and market uncertainty, which sends a negative investment signal that, all else equal, will impact operations, reliability and the provision of energy to consumers within the state.”

Smith said that if the proposed amendments are adopted, ERCOT’s governance structure will “most closely resemble” CAISO’s.

ERCOT Assistant General Counsel Jonathan Levine was unable to clarify the board’s next steps on the amendments during the Technical Advisory Committee’s short, virtual meeting Oct. 26.

“It’s a pretty fluid situation at this point. It’s up to the board and the board chair of what they want to do,” he said. “I apologize for not having any better information about where we’re heading on the bylaws amendment. I’m just a mouthpiece here.”

The Protocol Revision Subcommittee said it is working on a priority revision process that TAC shared with the board’s Reliability and Markets Committee in October. A draft will be presented during TAC’s Dec. 5 meeting. (See “TAC Shares Changes with R&M,” ERCOT Board of Directors Briefs: Oct. 18, 2022.)

Combo Ballot Approves TAC’s Annual Review

TAC’s combination ballot last week included the results of its annual structural and procedural review, two nodal protocol revision requests (NPRRs), a revision to the Load Profiling Guide (LPGRR), an other binding document request (OBDRR) and a change to the Retail Market Guide:

- NPRR1128: would set a 1-cent/MW lower ancillary service (AS) offer floor for fast frequency response (FFR) responsive reserve (RRS), thereby allowing, depending on relative AS offers, FFR procurement up to the current limit without proration with other RRS categories in the ancillary procurement process.
- NPRR1148: would resolve protocol gaps found during emergency contingency reserve service’s creation of its system change requirements.
- LPGRR069: would add Lubbock Power & Light’s service address zip codes to the guide and updates the ERCOT service territory map to include Lubbock County. The LPRR also corrects zip code counts that were omitted in the count column.
- OBDRR043: would align the operating reserve demand curve’s methodology with NPRR1148.
- RMGRR170: would define the inadvertent gain/loss (IAG) process and an IAG; clarify its appropriate use; and clarify the IAG process’ appropriate use.