NOTICE DATE: September 24, 2024

NOTICE TYPE: M-A092424-01 Operations

SHORT DESCRIPTION: ERCOT to issue an RFI to identify Private Use Networks that are industrial generation facilities

INTENDED AUDIENCE: Resource Entities with Generation Resources that are registered as part of a Private Use Network

DAYS AFFECTED: October 1, 2024, through October 30, 2024

LONG DESCRIPTION: To assist with Outage Coordination processes described in Section 3.1.6(7) of the ERCOT Protocols, ERCOT is issuing a Request for Information (RFI) to assist ERCOT in determining which Private Use Networks (PUN) should be considered an "industrial generation facility" (IGF), as that term is used in Public Utility Regulatory Act (PURA) § 39.151(l). 

ERCOT uses PUN registration for several purposes, including determining eligibility for net metering under the requirements of Section 10.3.2.3 of the ERCOT Protocols. The increase in the number of registered PUNs in recent years has also created challenges in coordinating outages.  Specifically, while Section 3.1.6(7) of the ERCOT Protocols generally exempts outages of Generation Resources in an Industrial Generation Facility (IGF) from the Maximum Daily Resource Planned Outage Capacity (MDRPOC) limit, ERCOT has had to rely on PUN registration as a proxy for IGF status because it lacks information on which PUNs are IGFs.  The basis for the IGF exemption from MDRPOC is a statutory prohibition against ERCOT rules that would “adversely affect or impede any manufacturing or other internal process operation associated with an industrial generation facility, except to the minimum extent necessary to assure reliability of the transmission network.” See PURA § 39.151(l).  Additional information can be found within ERCOT's presentation during the July ROS meeting.

For each PUN in the Network Operations Model that includes one or more Generation Resources, ERCOT will send an RFI, via DocuSign, to the Authorized Representative of the associated Resource Entity (RE).  The RFI will be sent on October 1, 2024 and must be completed by October 30, 2024. Each individually registered PUN requires a response. Therefore, REs associated with multiple PUNs will receive multiple DocuSign emails.  ERCOT is not sending the RFI to REs with PUNs that include Energy Storage Resources (ESR) or Settlement Only Generators (SOG), as ERCOT does not interpret the term "industrial generation facility" within the context of Section 39.151(l) to apply to ESRs, and SOGs are not required to coordinate their outages with ERCOT.

The RFI will contain the following, or similar, questions to help assess if a PUN should also be considered an IGF in ERCOT's systems:

• Do you believe that this PUN is an “industrial generation facility” as that term is used in PURA § 39.151(l)? If so, please explain why.
• Would ERCOT’s approval or rejection of an outage request for any Generation Resource in the PUN facility identified above adversely affect or impede any manufacturing or other internal process operation associated with an industrial generation facility?  If so, please explain how.
• Is the operation of any industrial process at your PUN facility physically dependent on the operation of one or more Generation Resources in the facility? If so, please explain this dependency.
• Does any Generation Resource at your Private Use Network facility generate electricity as a byproduct of an industrial process?  If so, please explain.

ACTION REQUIRED: ERCOT requests that all DocuSign responses be provided by October 30, 2024

CONTACT: If you have any questions, please contact your ERCOT Account Manager. You may also call the general ERCOT Client Services phone number at (512) 248-3900 or contact ERCOT Client Services via email at ClientServices@ercot.com.

If you are receiving email from a public ERCOT distribution list that you no longer wish to receive, please follow this link in order to unsubscribe from this list: http://lists.ercot.com.

dg