On November 10, 2021, ERCOT held a workshop on Generation Entity Winter Weather Preparedness.  At this workshop, ERCOT provided an explanation of its approach to implementing the Public Utility Commission’s Winter Emergency Preparedness Rule,[1] which was issued in August 2021 in response to legislative directives contained in Texas Senate Bill 3 (“SB 3”).  The new rule aims to ensure that the electric industry is prepared to provide continuous reliable electric service throughout this upcoming winter season and to comply with the statutory deadline for the adoption of weather emergency preparedness reliability standards set forth in SB 3.

The §25.55 Winter Preparedness Rule requires generator entities to fix any known, acute issues that arose during the 2020 – 2021 winter weather season and requires a notarized attestation from the highest ranking representative, official, or official with binding authority over each of the above entities attesting to the completion of all required activities.

The §25.55 rule represents the first of two phases in the commission’s development of robust weather emergency preparedness reliability standards.  The phase two reliability standards are not yet developed, and will ultimately consist of a more comprehensive, year-round set of weather emergency preparedness reliability standards that will be informed by a robust weather study currently being conducted by ERCOT in consultation with the Office of the Texas State Climatologist.

At the November 10 meeting, ERCOT provided an overview of the §25.55 rule, its compliance requirements, and several helpful resources to aid generation entities in their compliance efforts.  Below are several key takeaways from the meeting.

Compliance requirements

• By December 1, 2021, a generation entity must complete and submit a Winter Weather Readiness Report (“WWRR”) to ERCOT in accordance with 25.55.
• Generation entities must also submit a notarized attestation sworn to by the generation entity’s highest-ranking representative, official, or officer with binding authority over the generation entity attesting to the accuracy and veracity of the information in the WWRR.
• ERCOT has provided a WWRR Form for generation entities to complete via DocuSign.  A copy of that form can be found with the November 10 meeting materials.
• Staff clarified that the 25.55 requirement for submission of a WWRR is separate from the ERCOT Nodal Protocols Section 22, Attachment O requirement for Declaration of Completion of Generation Resource Winter Weatherization Preparations.

Requests for Good Cause Exceptions

• A generation entity may submit a notice asserting good cause for noncompliance. The notice must be submitted as part of the generation entity’s WWRR.
• Requirements for a request for good cause exception are contained in 25.55(c)(6)(A).
• After reviewing the request for good cause exception, ERCOT and the Commission may require the generation entity to correct the noncompliance and assign a cure period for completion of such correction.

Inspections

• ERCOT will conduct on site inspections of some generators during the period of December 2-23, 2021.  25.55(d).  ERCOT will schedule such inspections on an as-needed basis after reviewing the December 1, 2021 WWRR submissions.

Frequently Asked Questions

• ERCOT is maintaining a list of very helpful “frequently asked questions” on the weatherization initiative.  These items address many of the concerns raised by generation entities during the November 10 meeting.  ERCOT intends to continue updating the FAQ documentation as additional questions are raised.  A copy of the current FAQ document is included with the November 10 meeting materials.

[1] Weather Emergency Preparedness, 16 T.A.C. § 25.55 (2021).

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