This Nodal Protocol Revision Request (NPRR) strikes language which has the effect of creating an uncertain and indefinite obligation to provide ongoing Demand response capacity in an emergency.
Reason:
ERS Loads are paid an availability payment for participation in the ERS program, which is described as carrying an eight hour performance obligation. No additional energy payment is possible. While this is relatively long for many loads, it is definite and clear. The Section 3.14.3.3 language proposed to be stricken, however, creates an additional and indefinite obligation to remain deployed, which is unreasonable for loads to comply with, and has been the reason for many loads to drop out of or avoid participation in the ERS market. In its final decision in Project No. 39948, the Public Utility Commission of Texas (PUCT) stated: "The commission has, … modified subsection (d)(7) and (8) of the rule to ensure that ERCOT has the flexibility to develop procedures that would govern the ability of ERS resources to return from deployment after the maximum eight cumulative hours of deployment is reached during a contract period. Some potential ERS participants may not be able to stay offline for more than a given number of hours, or may incur unexpected or unreasonable costs with extended deployments, and the commission encourages ERCOT to explore program rules that satisfy ERCOT’s reliability needs and also provide participants with certainty about the maximum duration of a deployment and financial feasibility of participation in the program."