ERCOT Generation Updates: Impact of Recent Executive Orders and NPRR Discussions

WMWG UPDATE TO WMS FEBRUARY 5, 2025 AMANDA FRAZIER, WMWG CHAIR

AGENDA G EN ER AL I TEM S EPA I M PAC TS TO G EN ER ATI O N DI SC USSI O N ( VI STR A P R ESEN TATI O N ) N P R RS R EADY FO R WM S VOTE: N P R R 1256, SET TL EM EN T FO R M R A O F ESRS N P R R 1190, H D L OVER R I DE FO R I N C R EASED L SE CO STS N P R RS DI SC USSED BUT STI L L P ERCO L ATING : N P RR1229, RTM C MP EN ERGY PAYMEN T C AR D/ C R R BA AL LO C ATION DI SC USSI ON

GENERAL ITEMS WMWG on January 30, 2025 Susana Hildebrand (Vistra) presented a brief overview of Trump administration appointees and new Executive Orders / Presidential Memoranda impacting ERCOT generation and the electric industry. The presentation focused on the Unleashing American Energy Executive Order which is expected to have the largest impact on environmental issues and energy through: Recission of Biden administration s executive orders Restriction of environmental analyses under NEPA to accelerate permitting Reviewing the EPA s Endangerment Finding for greenhouse gasses Pausing disbursements and reviewing policies of IRA and IIJA The new Attorney General may provide notice of this Executive Order to courts with jurisdiction over pending litigation including the Good Neighbor Plan and Legacy Coal Combustion Residuals Rule. Changes to active regulations may impact publicly announced retirement dates for aging coal generators.

NPRRS READY FOR WMS NPRR1190, High Dispatch Limit Override Provision for Increased Load Serving Entity Costs. Remanded to TAC by ERCOT Board of Directors on October 10, 2024 to allow time for stakeholder compromise on compensation to generators impacted by HDL overrides. Reliant Energy submitted Comments on January 30, 2025, which would create an annual $10M cost threshold that would trigger a review of operational and Settlement aspects of HDL override payments. Residential Consumers indicated appreciation for the Reliant proposal but acknowledged that consensus may not be possible. No further discussions are planned for WMWG. NPRR1256, Settlement for MRA of ESRs. ERCOT presented January 27, 2025 Comments which addressed stakeholder concerns about ESR state of charge in relation to Settlement equations for MRA standby payments. The revised formulas introduce a Standby Payment reduction factor that would reduce MRA ESR standby payments proportionally based on energy available relative to the contracted quantity. There was no opposition to the revised language and stakeholders expressed appreciation for the quick turnaround.

NPRRS THAT REQUIRE MORE DISCUSSION NPRR1229, Real-Time Constraint Management Plan Cost Recovery Payment. Previous WMWG discussions explored a combined cost threshold between NPRR1190 and NPRR1229. Reliant Energy and LCRA recommended decoupling these discussions given the absence of stakeholder consensus on NPRR1190. ERCOT clarified that cost recovery was limited to Resources that trip off-line during a contingency following a real-time VDI instruction from ERCOT Resources that agree to a CMP would not be eligible for cost recovery under this framework. STEC is considering Residential Consumers recommendation to clarify the title and language of NPRR1229 with further comments.

CARD/CRRBA ALLOCATION DISCUSSION Austin Rosel (ERCOT) provided an update on stakeholder-requested analyses of CARD allocation methods. The final analysis by Zone for each method (current, Vistra, IMM, City of Georgetown) will be presented during the March 3, 2025, WMWG meeting. ERCOT will also present a seven-year analysis of TCOS and CARD / CRRBA, an analysis of congestion rent by zone, and the impact of moving to a non-zonal approach for each allocation method. Vistra is also intending to present additional information on CARD allocation at the upcoming March 3, 2025, WMWG meeting.

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