Hi Chad and David,

Attached are my redline comments on Item 91 on behalf of Hunt Energy Network for discussion at PDCWG tomorrow. Please share this with PDCWG email list (copying me if possible) since I cannot post there. These comments are still being worked on and I’m waiting on some possible feedback from ERCOT as well – so I’d appreciate any feedback from PDCWG and WMWG members and may update the document based on feedback received.

I look forward to discussing this tomorrow and receiving any feedback prior to that meeting. Chad and David, please let me know that you’re received this email.

Regards,

Shams Siddiqi, Ph.D.

President, Crescent Power, Inc.

Tel: +1.512.619.3532

Email: [log in to unmask]

www.CrescentPower.net

Here is the document associated with issue 91.  Please review. 

David Detelich

PDCWG Members,

I have attached the information collected by those assigned to work on Items 91, 100, and 10X of the TAC-owned Emergency Conditions List.  The assignees were Marty & Ian, who are copied on this email.

Please review their notes, and send any questions or comments back to them for further consideration.  If they do not get further questions or comments, then we can send this summary to the ROS, and request closure of the PDCWG work on these topics.

Chad – Ian Haley and I have composed responses to the Emergency Conditions List for our assigned items 91, 100 and 100x (120) in the attached document.  Is there anything else you would like us to do with these items for PDCWG?

We would like to suggest more discussion regarding:

Item 91 - Could fast frequency response play a bigger role?  This item does not ask the next question regarding what why batteries aren’t bidding FFR. 

Some market participants have identified the following reasons to change the procurement of FFR (not related to this event):

• In the DAM market, FFR quantities are awarded as part of the load response hourly RRS requirements.  The maximum quantity of FFR that can be provided is 450 MWs.  The load response RRS bidding process is oversubscribed, and the awards are often pro-rated 60% plus of the offered quantities by the resources.
• As opposed to the original vision for FFR, the arrangement of the pro ration of FFR awards and the combination model structure have had the unintentional consequence where FFR is not financially attractive to ESR suppliers.  As the ERCOT Winter event presentation shows, the ESR Market is responding to the DAM AS Market by bidding RRS as a generator and load as RRS, regulation down and FRRS Down.

We think these issues should be discussed at a policy working group such as WMWG.

713-557-0013

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