I attached the initial version of the KTC I spoke about this morning.
Note that I will be brining back a heavily edited version, based on my edits and upcoming discussion with ERCOT, planning on November WMWG. If you are interested in working on edits with me, please let me
know [log in to unmask]
Below are the bullet points I spoke to this morning:
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KTC 15-3 is regarding Switchable Energy Storage Resources
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Last discussed at WMWG in October 2021
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Basically, this is regarding a switchable battery energy storage resource like the existing Switchable generation resources
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The KTC goes through the following topics to be addressed in future protocol changes:
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Reliability and operations
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Settlements
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And then those following legal and policy decisions
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The legal and policy issues are:
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A FERC order will be needed to address charging an SWESR with electric energy from the transmission grid in one region, which is a fully FERC-jurisdictional region such
as SPP or MISO, and discharging that electric energy into the transmission grid in the non-FERC-jurisdictional region of Texas administered by ERCOT (or vice versa) and ensuring that such activity is fully authorized pursuant to FERC’s exercise of its limited
jurisdiction authority, which fully preserves the non-FERC-jurisdictional transmission grid in ERCOT
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Clarification from the PUC will be needed as to whether an SWESR must obtain a CCN prior to seeking an order from FERC seeking “limited FERC jurisdiction” approval for
the delivery of electric energy from one jurisdiction (RTO or ERCOT) into the SWESR for charging purposes and then redelivering that electric energy from the SWESR for discharging purposes into another jurisdiction
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Issue
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Protocols would not be developed until those FERC and PUCT issues are resolved, so unlike other KTCs, protocol development would not follow immediately after the KTC
passes. So we wanted to get this right.
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Next Steps
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An initial draft was prepped by ERCOT and shown at WMWG in October 2021
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The KTC needs to be approved by ROS and WMS and then TAC
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As discussed, it would probably sit until someone got the PUCT and FERC orders
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Jupiter has been working with ERCOT on revisions on this.
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My timeline is to come back to November WMWG
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Maybe helpful if those interested in working on revisions reached out to me in the next two weeks.
Caitlin Smith
Senior Director, Regulatory, External Affairs & ESG
O:512.937.6574
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M:832.326.1238
