NPRR473  Process for Submission of Generation Resource Weatherization Information

This Nodal Protocol Revision Request (NPRR) creates a process to accommodate the legislatively mandated submission of generator emergency operations plans. (See Texas Utilities Code § 186.007(f) Weather Emergency Preparedness Report - ("An electric generation entity within the ERCOT power region shall provide the entity’s [emergency operations] plan to ERCOT in its entirety.")). ERCOT has previously requested these plans pursuant to its authority under paragraph (i)(2)(H) of P.U.C. Subst. R. 25.362, Electric Reliability Council of Texas (ERCOT) Governance , which requires ERCOT to provide "[a]n assessment of the reliability and adequacy of the ERCOT system during extremely cold or extremely hot weather conditions, including information regarding steps to be taken by power generation companies and utilities to prepare their assets for extreme weather events." Based on its authority under this statute and rule, ERCOT believes it appropriate to create a formal process for submission of emergency operations plans and plan updates; to recognize the confidential status of information contained in these plans. ERCOT also proposes to require separate submission of weatherization plans for each Generation Resource, as the bulk of the emergency operations plans previously submitted do not pertain to weatherization, and requiring ERCOT to sort through lengthy plans to identify parts that may or may not be intended to apply to weatherization procedures imposes a substantial administrative burden. ERCOT expects that some Resource Entities may prefer to simply extract and submit the existing weatherization portions of existing emergency operations plans, while other Resource Entities may wish to create new plans providing greater detail of weatherization practices. Furthermore, in order to fulfill its regulatory obligation to assess ERCOT System reliability in extreme weather conditions, ERCOT must ensure that plant operators are in fact following the weatherization procedures described in the submitted weatherization plans. ERCOT therefore proposes a semi-annual weatherization declaration to determine ERCOT System preparedness. This declaration would represent that the Resource Entity (or other Entity responsible for the physical operation of a Generation Resource) has completed all weatherization preparations for the upcoming summer and winter season. Finally, in addition to expanding the categories of Protected Information to include emergency operations plans and weatherization plans, ERCOT proposes revisions to paragraph (p) of Section 1.3.1.1 to clarify that all information designated as Protected Information is considered Protected Information, unless it is expressly deemed otherwise by Section 1.3.1.2, Items Not Considered Protected Information, or is no longer confidential, as provided by Section 1.3.3, Expiration of Confidentiality. Existing language could be read to provide that any information a Market Participant is required to submit is not considered Protected Information. Also, the express exclusion of information provided in support of a Reliability Must-Run (RMR) application is redundant of an identical exclusion in paragraph (f) of Section 1.3.1.2.