Meeting Summary - NOGRR245 - 08/08/24 Review of Current Status

NOGRR245 Update – Slides

1 – Background of NOGRR245 - ERCOT Staff

• ERCOT filed the original NOGRR on January 11, 2023, following NERC recommendations due to IBR failures during system disturbances.
• IEEE 2800 was approved on February 8, 2023, leading to the NOGRR being tabled and referred to various working groups.
• Between February and September 2023, multiple comments were filed by market participants and others.
• On 9/14/2023, ROS granted NOGRR urgent status and recommended approval with amendments.
• TAC tabled the NOGRR on September 27, 2023, and more comments were filed until March 2024.
• On 3/27/2024 and 6/7/2024, TAC voted for recommending the NOGRR with various amendments from different groups.
• Leading to 6/17/2024, joint commenters filed opposition to the TAC recommended version, threatening to appeal if approved.
• ERCOT requested to table the NOGRR until August to address concerns of joint commenters.
• ERCOT board tabled NOGRR245 on June 18, 2024, based on ERCOT’s request.
• Since then, ERCOT staff worked on revisions with joint commenters to retain near-term benefits and bifurcate exemption processes.
• Revisions aimed to clarify or obtain JC agreement, remove redundancy, correct errors, and respond to joint commenters’ concerns.
• ERCOT plans to recommend making the subsequent bifurcation of NOGRR a board priority to be effective by April 1, 2025 to coincide with the deadline for submitting exemption requests.

2 – Basis of changes to TAC recommended version – ERCOT Staff – Clarification/JC Concern

Changes made to the TAC recommended version of NOGRR245:

• Key changes include clarification that output reductions due to wind speed or solar irradiance changes are exempt from penalties during ride-through events.
• Frequency ride-through and voltage ride-through requirements were updated.
• Added requirement for resources to inform ERCOT on maximized ride-through capability for modeling.
• Clarified deadlines for completing modifications and related notifications.
• Added clarity on compliance during the fault and recovery periods.
• Increased transparency on reporting resource maximization status to ERCOT.
• Clarification on the exemptions or extensions for meeting new requirements and reporting responsibilities.
• Modified information requirements for frequency and voltage ride-through capability reports.
• Resource entities must explain efforts to verify technical limitations if unable to get OEM or consultant verification.
• Stated that ERCOT will protect confidential information submitted in reports.
• Specified requirements for timely submission of extension requests by April 1, 2025.

2.1 – Basis of changes to TAC recommended version - ERCOT Staff – Bifurcation

Movement to the bifurcation bucket for changes:

• Changes made to accommodate moving exemption process criteria to a new NOGRR.
  • Section 2.6.2.1(7): Resources must submit frequency ride through capability report and request exemptions by 4/1/25. Criteria for granting exemptions will be established in the new NOGRR.
  • Section 2.12.1(1): Existing facilities not meeting ride through requirements must request an extension or exemption by 4/1/25. Criteria for exemptions to be determined in subsequent NOGRR.
  • Section 2.12.1(2): Exemption requests can only be supplemented with additional information under the new NOGRR process. No new exemption requests allowed after 4/1/25.
  • Section 2.12.1.3: Removed exemption from the title; now applies only to extensions.
  • Sections 2.12.1.3(3),(4), and (5): Removed references to exemptions, addressed in new NOGRR.
  • Sections 2.12.1.4(6) and (7): Removed references to exemptions, addressed in new NOGRR.

2.2 – Basis of changes to TAC recommended version - ERCOT Staff – Corrections

Bucket three corrections involved errors in the version approved by TAC:

• 2.9.1.1(1) contained typographical errors in formulas in tables A and B.
• 2.9.1.1(8), renumbered, corrected paragraph numbers due to a deletion and requires entities to complete maximization by 12/31.
• 2.9.1.2(7) was renumbered to accommodate changes.
• 2.12.1(1) corrected section references.
• 2.12.1.4 had its title removed and subsections were renumbered as part of 2.12.1.3.

2.3 – Basis of changes to TAC recommended version - ERCOT Staff – Redundancies

Removal of redundant or duplicative requirements in Operating Guide sections 2.9.1.1 and 2.12.1, focusing on avoiding duplication with IEEE 2800 standards:

• Removed Table C in 2.9.1.1(1)
• Revision and deletion of sections related to initial frequency and voltage ride-through capability reports to avoid redundancy and address objectionable language.
• Shift in focus to discuss next steps and address questions/concerns
• Upcoming discussions on August 19th in the R&M Committee regarding NOGRR245 and presentation of RFI results in line with NERC recommendations.
• Board’s consideration of NOGRR245 on August 20th, aiming for approval and subsequent filing of a new NOGRR to develop exemption criteria by April 1st of next year.
• Explanation of the process and timeline for compliance with new requirements, including potential TAC workshops to ensure expedited implementation.
• Feedback from stakeholders indicating anticipation for the redlined version and concerns about timeline constraints in the exemption criteria update process.
• Discussions about potential conflicts and access issues regarding IEEE 2800 standards, suggesting the need for reconsideration of including specific guidelines internally.
• Clarification of the PGRR109 timeline for ERCOT and TSP review of dynamic models with the intent to expedite processes for ride-through capability improvements.
• Stakeholder concerns about the practicality and timeline for meeting new requirements, with assurances of efforts to facilitate and expedite the process within allowed regulations.

3 – Description of How the Process Will Work, if Approved – ERCOT Staff

Requirement:

• By December 31, 2025, or the synchronization date, resources under construction must meet these requirements.
• Maximize software firmware settings and parameterization, including memory upgrades if necessary.
• Inform ERCOT when maximized to meet or exceed section 2.6.2.1(1)-(5) and IEEE 2800, as referenced in section 2.9.1(8).
• Report initial frequency ride through capability by April 1, 2025, if unable to maximize by the end of 2025.

Report Content:

• The initial frequency ride through capability report must contain information outlined in section 2.11.1(1) including:
  • Resource entity’s D-U-N-S number.
  • Software firmware settings and parameterization modifications.
  • Site name
  • Description of post-modification limitations.
  • Compliance with May 1, 2024, requirements until maximization.

Voltage Ride Through Requirement:

• For pre-8/1/24 resources, meet or exceed section 2.9.1.2(1)-(7) by 12/31/25 or the commercial operation date.
• Submit initial report by April 1, 2025, and request extension if unable to meet requirements by the deadline.
• Resources that meet 2.9.1.2 before 1/1/28 are exempt from IEEE 2800.

Additional Requirements: During exemption, extension, or appeal process, the resource must:

• Meet the greater of its maximized capability or requirements in effect on 5/1.
• Submit an implementation plan within 90 days if new software firmware setting modifications are available.
• Notify ERCOT upon completion of maximization.
• For resources with SGIA after 8/1/24 or undergoing significant modifications, frequency and voltage ride through standards to meet IEEE 2800 by the synchronization date.
• Request extension if unable to comply by the deadline.

Performance Failures: If a performance failure occurs:

• Investigate, report the cause, validate the model, and develop a mitigation plan.
• Implement the approved plan within 180 days.
• ERCOT may report failures to the reliability monitor if criteria are not met.

Exemption and Extension Process Highlights:

• Requests must be submitted by 4/1/25
• For pre-8/1/24 Resource, must accompany IFRTCR/IVRTCR
• For Resource with approved exemption/extension, max capabilities become performance criteria until it ends.
• Until exemption/extension/appeal is final, pre-8/1/24 AGIA Resource must meet greater of: (i) max capability, or (ii) requirements in effect on 5/1/23

Extension Timeline: Process and timeline for reviewing extension requests:

• ERCOT confirms receipt and completeness of requests.
• Requests additional information if needed.
• ERCOT will try to complete the process within 180 days or provide an estimated timeline.
• Aggrieved entities can appeal ERCOT’s decisions to the PUC under procedural rule 22.251.
• If no appeal, entity deemed to have accepted ERCOTs decision

4 – Questions – ERCOT Staff

• Question on repowering and replacing WTG units with type four by 4/1/27.
• Discussion about whether criteria for type 2 sites need to be submitted; confusion over criteria definitions.
• Issue of legacy units and facility’s reluctance to invest in modeling for SGIA signed before 8/1/2024. Need for specific answer and SME consultation recognized by ERCOT representative.
• Replacement work will take place from March to June 2026, site offline during this period.
• Clarification on adherence to IEEE 2800 for legacy IBR plants: must maximize capability, not just comply with minimum standards. Emphasis on maximizing equipment capabilities, not just meeting baseline requirements.
• Discussion on performance failures and requirements for software updates and hardware changes. Importance of holistic approach to evaluate facility settings and controls ensuring voltage ride-through capability.
• All exemption requests have to be in 4/1/25.
• Exemptions discussion: plants need to ask by 4/1/25 if unable to meet IEEE 2800 but should be beyond 2.9.1.2.
• Engineering concerns integrated in maximization to avoid equipment damage.
• Meeting concluded with no further questions, slides were made available for understanding procedures.

5 – Adjourn