Vote tallies here reflect individual votes, not the weight of the votes by market segment.
Affirmative votes are not recorded in these vote tallies. For additional details on the voting
record, please consult the Recommendation or Action Report, or the official vote tally if
available, as posted in the key documents.
Aug 8, 2012
220.127.116.11, 3.21 (new), 22K (new)
This Nodal Protocol Revision Request (NPRR) creates a process to accommodate the legislatively mandated submission of generator emergency operations plans. (See Texas Utilities Code § 186.007(f) Weather Emergency Preparedness Report - ("An electric generation entity within the ERCOT power region shall provide the entity’s [emergency operations] plan to ERCOT in its entirety.")). ERCOT has previously requested these plans pursuant to its authority under paragraph (i)(2)(H) of P.U.C. Subst. R. 25.362, Electric Reliability Council of Texas (ERCOT) Governance , which requires ERCOT to provide "[a]n assessment of the reliability and adequacy of the ERCOT system during extremely cold or extremely hot weather conditions, including information regarding steps to be taken by power generation companies and utilities to prepare their assets for extreme weather events." Based on its authority under this statute and rule, ERCOT believes it appropriate to create a formal process for submission of emergency operations plans and plan updates; to recognize the confidential status of information contained in these plans.
ERCOT also proposes to require separate submission of weatherization plans for each Generation Resource, as the bulk of the emergency operations plans previously submitted do not pertain to weatherization, and requiring ERCOT to sort through lengthy plans to identify parts that may or may not be intended to apply to weatherization procedures imposes a substantial administrative burden. ERCOT expects that some Resource Entities may prefer to simply extract and submit the existing weatherization portions of existing emergency operations plans, while other Resource Entities may wish to create new plans providing greater detail of weatherization practices.
Furthermore, in order to fulfill its regulatory obligation to assess ERCOT System reliability in extreme weather conditions, ERCOT must ensure that plant operators are in fact following the weatherization procedures described in the submitted weatherization plans. ERCOT therefore proposes a semi-annual weatherization declaration to determine ERCOT System preparedness. This declaration would represent that the Resource Entity (or other Entity responsible for the physical operation of a Generation Resource) has completed all weatherization preparations for the upcoming summer and winter season.
Finally, in addition to expanding the categories of Protected Information to include emergency operations plans and weatherization plans, ERCOT proposes revisions to paragraph (p) of Section 18.104.22.168 to clarify that all information designated as Protected Information is considered Protected Information, unless it is expressly deemed otherwise by Section 22.214.171.124, Items Not Considered Protected Information, or is no longer confidential, as provided by Section 1.3.3, Expiration of Confidentiality. Existing language could be read to provide that any information a Market Participant is required to submit is not considered Protected Information. Also, the express exclusion of information provided in support of a Reliability Must-Run (RMR) application is redundant of an identical exclusion in paragraph (f) of Section 126.96.36.199.
ERCOT is obligated by statute and by P.U.C. Subst. R. 25.362 to collect emergency operations plans and to assess reliability of the ERCOT System during extreme weather. This NPRR removes the need for future Market Notices and will provide greater transparency of ERCOT’s collection and intended use of this information.