NOTICE DATE: April 8, 2022

NOTICE TYPE: M-A040122-02 Legal

SHORT DESCRIPTION: Additional Information and Clarification Regarding Submission of Unredacted EOPs to ERCOT by Entities Subject to Newly Amended 16 TAC § 25.53

INTENDED AUDIENCE: Resource Entities, Load Serving Entities, and Transmission and/or Distribution Service Providers

DAY AFFECTED: April 18, 2022

LONG DESCRIPTION: ERCOT provides the following additional information and clarification regarding the submission of unredacted Emergency Operations Plans (EOP) to ERCOT:

General submission deadline extended to April 18, 2022

On April 5, 2022, the Public Utility Commission of Texas (PUC) issued a memorandum extending the deadline for filing EOPs and related documents from April 15, 2022 to April 18, 2022. Consequently, the deadline for submitting unredacted EOPs to ERCOT is now April 18, 2022. This deadline does not apply to municipally owned utilities (MOUs), as noted below.

EOP submission deadline for MOUs is June 1, 2022

16 TAC § 25.53(c)(1)(B) allows MOUs until June 1, 2022 to file their EOPs and summaries. ERCOT’s initial Market Notice addressing the submission of EOPs did not address this different deadline for MOUs. ERCOT clarifies that MOUs may submit their unredacted EOPs to ERCOT as late as June 1, 2022, consistent with the rule.

A Market Participant may submit an EOP on behalf of itself and/or other entities

Some Market Participants have asked whether a Market Participant can submit an EOP on behalf of one or more other entities, given that certain entities required to submit an EOP may lack the required Digital Certificate. ERCOT confirms that any Market Participant may submit an EOP on behalf of one or more other entities (irrespective of whether these entities have the required Digital Certificate) so long as (1) the submitted EOP applies to each such entity and (2) the submitting Market Participant has been authorized by each such entity to submit the EOP on that entity’s behalf. So, for example, if two Power Generation Companies (PGCs) are represented by the same Qualified Scheduling Entity (QSE), and the same EOP applies to each PGC, then the QSE may submit that EOP on behalf of both PGCs through a single Service Request, so long as the QSE has been authorized by each PGC to submit the EOP on the PGC’s behalf. The submitting entity itself (whether QSE or otherwise) need not be one of the entities required to submit an EOP under 16 TAC § 25.53. By submitting an EOP on behalf of another entity, the submitting entity is confirming that it has authorization to submit the EOP on behalf of the entity for which the EOP was submitted.

Only one EOP should be submitted per Service Request

While an EOP may be submitted on behalf of multiple entities, ERCOT requests that each Service Request include only one EOP, to avoid confusion about which EOP applies to which entity (or entities).

ERCOT reminds Market Participants that if submission of the EOP using a Service Request is not feasible for any reason—including that an entity does not have a Digital Certificate—it may contact its ERCOT Account Manager to inquire about an alternative submission method.

ACTION REQUIRED: Each Market Participant that is required to maintain an EOP pursuant to 16 TAC § 25.53 should submit its EOP to ERCOT by April 18, 2022 using the procedures described in ERCOT’s Market Notice published on April 1, 2022, as clarified by this Market Notice.

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 [log in to unmask].

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NOTICE DATE: April 1, 2022

NOTICE TYPE: M-A040122-01 Legal

SHORT DESCRIPTION: Submission of Unredacted EOPs to ERCOT by Entities Subject to Newly Amended 16 TAC § 25.53

INTENDED AUDIENCE: Resource Entities, Load Serving Entities, and Transmission and/or Distribution Service Providers

DAY AFFECTED: April 15, 2022

LONG DESCRIPTION: The Public Utility Commission of Texas (PUC) recently amended 16 Texas Administrative Code (TAC) § 25.53 to implement the requirements of Utilities Code § 186.007, as amended by Senate Bill 3. The revised rule requires each “entity”—defined to include an electric utility, transmission and distribution utility (TDU), power generation company (PGC), municipally owned utility (MOU), electric cooperative, retail electric provider (REP), and ERCOT—to develop and maintain an emergency operations plan (EOP) that meets certain content requirements established by the amended rule. The rule became effective March 20, 2022.

Subparagraph (c)(1)(B) of the amended rule requires that, “[f]or an entity with operations within the ERCOT power region, the entity must submit its unredacted EOP in its entirety to ERCOT.” The PUC has confirmed that EOPs must be submitted to ERCOT by April 15, 2022, which is also the deadline established by the rule for filing the summary of the EOP and a redacted version of the EOP with the PUC.

To accommodate EOP submissions with large file sizes and to ensure security of these communications, ERCOT requests that each affected Market Participant submit its EOP to ERCOT using the Service Requests application on the Market Information System (MIS) in the manner described in this Market Notice. Note that this submission method will require the Market Participant’s Digital Certificate holder to be assigned the “MP_ASSETS” role by the Market Participant’s User Security Administrator (USA). ERCOT strongly encourages each Market Participant to ensure that the Digital Certificate holder who will submit the EOP has been assigned this role well before the April 15 submission deadline.

An eligible Digital Certificate holder may submit the EOP to ERCOT by logging on to the MIS, accessing the Service Requests application, clicking on “Create Service Request,” clicking on the “plus” sign at the bottom of the Service Request window to enable text entries in the fields, and then completing the request fields as follows (see attached document for visual explanation):

Enter the requested contact phone number and email address.
Select “MP Registration” under the “Request Type” drop-down menu.
Select “Registration Changes – NCI” under the “Request Sub-Type” drop-down menu.
For the “ESI ID” field, no entry should be provided; any entry will be disregarded.
For the “Short Description” field, enter “Rule 25.53 EOP Submission” and provide the entity’s PUC registration category or entity type (i.e., PGC, TDU, MOU, Electric Cooperative, or REP). For example, the Short Description for a submission by a PGC should read: “Rule 25.53 EOP Submission – PGC.” If the EOP is being submitted on behalf of multiple entities, and the entities do not have the same PUC registration category or entity type, then the entity should indicate the applicable entity types in the Short Description (e.g., “Rule 25.53 EOP Submission – PGC/REP”). The Market Participant should not include the ERCOT Market Participant category (e.g., Resource Entity, Load Serving Entity) in the Short Description.
For the “Long Description” field, provide the full legal name of each entity for which the EOP is being submitted and the PUC registration category or entity type (e.g., “Generator Company LLC (PGC)”). For entities registered with the PUC, the entity name must match the name used for registration with the PUC.
Click on the green submission button below the Long Description field to submit the service request. The service request must be submitted before the EOP may be attached to the service request.
Once the service request has been submitted, an “Attachments” field will appear below the service request field. Attach the EOP to the service request by clicking the “plus” sign below “Attachments” and adding each necessary file. The attachment may be added to the service request by clicking on the green submission button at the bottom of the Attachment field. Multiple files may be attached.

If the EOP is being submitted on behalf of an entity that is also registered with ERCOT as a Resource Entity, and the entity is also intending the submission to satisfy the Resource Entity’s EOP submission obligation under Section 3.21 of the ERCOT Protocols, the entity should also include the following information in the Long Description:

The legal name of each ERCOT-registered Resource Entity for which the EOP is being submitted;
A statement that the EOP is being submitted to satisfy the Resource Entity’s EOP submission obligation under Section 3.21 of the ERCOT Protocols;
The unit code or site code of each Generation Resource or Energy Storage Resource to which the EOP applies; and
A clear identification of each specific part of the EOP that addresses weatherization, unless the Resource Entity maintains a separate, standalone weatherization plan, as required by paragraph (2) of Section 3.21.

Once the service request has been submitted, the active service request will serve as proof of submission. Once ERCOT has reviewed the service request and downloaded the EOP, ERCOT will send an email to the submitter confirming receipt. ERCOT expects that it may take several weeks to process all of the service requests, given the large number of EOPs that will need to be submitted.

Any future updates to an entity’s EOP may be submitted in this manner unless ERCOT issues a subsequent Market Notice providing otherwise. ERCOT will also post these instructions on its website.

Any entity registering with the PUC after the April 15, 2022 submission deadline should submit its EOP to ERCOT using the procedures described above, unless ERCOT issues a subsequent Market Notice providing otherwise.

If a Market Participant determines that submission of the EOP using this Service Request method is not feasible, it should contact its ERCOT Account Manager to inquire about an alternative submission method.

Any entity that is required to submit an EOP to ERCOT but that is not a registered Market Participant with ERCOT may contact ERCOT Client Services for further guidance at [log in to unmask].

ERCOT will regard all unredacted EOPs as Protected Information, as required by 16 TAC § 25.53(c)(1)(C).

ACTION REQUIRED: Each Market Participant that is required to maintain an EOP pursuant to 16 TAC § 25.53 should submit its EOP to ERCOT by April 15, 2022 using the above procedures.

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