by Kelso King, Grid Monitor
EDF Energy Services, LLC (EDF) is a registered power marketer and qualified scheduling entity (QSE). ERCOT procures Responsive Reserve Service (RRS) to maintain system frequency at 60 Hz and all generation units providing RRS are required to reserve frequency responsive capacity.
Staff asserted that, between March 27, 2016 and December 28, 2017, there were 113 operating hours for which EDF failed to reserve sufficient capacity to meet its RRS obligations.
EDF asserted that a calculation error resulted in inaccurately telemetered non-frequency responsive capacity (NFRC) values leading to the appearance of a lack of headroom.
Staff asserted that:
• NFRC miscalculations did not fully account for EDF’s capacity shortfalls
• EDF had an obligation to telemeter accurate NFRC values; and
• Failing to reserve sufficient capacity to meet an RRS obligation and failing to telemeter accurate data can each pose a reliability risk to the bulk electric system.
On December 3, 2019, the parties entered into a settlement agreement between Staff and EDF resolving the violations. EDF agreed to pay an administrative penalty of $475,000.
On January 29, 2020, Commissioner D’Andrea filed a memo recommending that the Commission direct Staff to provide additional information to clarify what actions EDF Energy Services, LLC took to prevent future ancillary services capacity shortfalls and rectify the telemetry errors. He suggested that Responsive Reserve Service (RRS) is one of ERCOT’s most important ancillary services and that market participants involved in the provision of RRS must ensure they reserve enough capacity to meet their RRS obligations. Commissioner D’Andrea asserted that the findings of facts in the proposed order “neither clearly document what occurred to lead to the investigation nor describe what mitigating actions EDF has taken or will take to avoid these problems in the future.” Commissioner D’Andrea directed Staff to address a list of seven questions in a filing no later than February 7, 2020.