NOTICE DATE:  November 13, 2024

NOTICE TYPE: M-A111324-01 Operations

SHORT DESCRIPTION: Results of ERCOT Reliability Monitor (ERM) Reactive Testing Compliance Audit

INTENDED AUDIENCE:  Qualified Scheduling Entities (QSEs) and Resource Entities (REs)

LONG DESCRIPTION: In 2023, the ERM conducted an audit of Market Participant compliance with Nodal Operating Guide §§ 3.3.2.2(5) and (7). The ERM submitted a confidential Compliance Audit Report to the PUCT on December 11, 2023 and opened Incident Reviews for Market Participants significantly out of compliance. The ERM is issuing this notice following the conclusion of those Incident Reviews because many Market Participants remain out of compliance.

ERCOT Operating Guide § 3.3.2.2(5) requires REs to complete a reactive verification test for Generation Resources at least every five years. The requirement includes “lagging” and “leading” reactive tests. Further, Operating Guide § 3.3.2.2(7) requires REs to timely and accurately report test results to ERCOT and the QSE representing the Generation Resource. The RE must, “properly complete all required data fields in the NDCRC [Net Dependable Capability and Reactive Capability] application for a test to be considered valid.”

The ERM’s audit revealed significant noncompliance across Market Participants. Sixty-four percent of overdue Resources were more than one year late in conducting and filing the results of leading reactive tests. Sixty-eight percent of overdue Resources were more than one year late in conducting and filing the results of lagging reactive tests.

Market Participants are urged to create internal controls to ensure they timely meet the requirements in the future. Failure to timely perform reactive tests is subject to enforcement action by the Public Utility Commission of Texas (PUCT). As a result of this Compliance Audit, the ERM referred to the PUCT Division of Compliance and Enforcement (DICE) confidential reports regarding delinquent Market Participants on October 30, 2024 for possible enforcement action at the PUCT’s discretion.

ADDITIONAL INFORMATION: See also M-A041723-01 Notice of ERCOT Reliability Monitor Compliance Audit (April 17, 2023).

CONTACT: If you have any questions, please contact the ERCOT Reliability Monitor (ERM) at erm@ercot.com.

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mm/dg