NOTICE DATE: September 25, 2019

NOTICE TYPE: M-C092519-01 Operations

SHORT DESCRIPTION: TCEQ Enforcement Discretion for Certain Generation Resources Needed to Resolve Transmission Congestion in West Texas

INTENDED AUDIENCE: ERCOT Market Participants

DAY AFFECTED: Ongoing

LONG DESCRIPTION: Today, in response to an ERCOT request, the Texas Commission on Environmental Quality (TCEQ) has notified ERCOT of its intention to exercise enforcement discretion in evaluating Luminant Generation Company LLC’s (“Luminant”) compliance with its TCEQ air-permit emissions limits for the Permian Basin Generation Resources (“Permian Units”) when they are needed to address certain ERCOT-declared transmission emergencies impacting West Texas.  Both letters are attached to this Notice. 

ERCOT requested the TCEQ’s consideration of enforcement discretion due to unique circumstances impacting reliability in West Texas.  Substantial Load growth in the region has resulted in occasional limit exceedances on the import paths into the region, and the transmission additions that will help mitigate this congestion will not be completed until late 2020 and early 2021.  In the meantime, ERCOT must rely on the Permian Units to help relieve this congestion, as these are the only Generation Resources with Shift Factors of a magnitude sufficient to enable SCED to resolve the relevant transmission constraints.  However, because the Permian Units are approaching their 2019 emissions limitations under their TCEQ-issued air permits, enforcement discretion will likely be necessary for the remainder of this year if these units are to remain available to ERCOT to address these emergencies.  Without these units, ERCOT expects that it may need to shed Load in West Texas to avoid the risk of cascading outages. 

The conditions under which enforcement discretion will be available are detailed in the attached ERCOT Policy Concerning TCEQ Enforcement Discretion Relating to Transmission Emergencies in West Texas.  Under this Policy, enforcement discretion will be available to Luminant only when ERCOT has issued an Emergency Notice declaring a transmission emergency and has committed one or more of the Permian Units via a Reliability Unit Commitment instruction.

The enforcement discretion described in this Policy does not affect the TCEQ’s potential exercise of enforcement discretion under the existing Procedure for Requesting TCEQ Enforcement Discretion Relating to a Power Emergency in Texas for ERCOT, MISO, or SPP Regions.   All TCEQ-related policy documents will be posted on ERCOT.com under Grid Information.

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 ClientServices@ercot.com.

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