Is Texas Ready for Winter?

As winter approaches, vulnerable Texas dithers and grumbles. Weather resilience is important in the Lone Star State, where intense summer heat and deep winter freezes have often crippled the Electric Reliability Council of Texas (ERCOT), the state-wide, autarkic electric grid. Winter Storm Uri in February 2021 caused many of dollars in economic damage and over 200 deaths in Texas, according to the Texas comptroller.

Winter Storm Uri, Feb. 2021: 69% of customers lost power, over 200 Texans died

As the specter of winter’s past arrives, ERCOT and the Public Utility Commission of Texas (PUCT) are squabbling over preparedness. Part of the problem in Texas is the continued political might of the natural gas industry and antipathy toward advanced technologies, specifically battery electric storage as an aid to short-term supply.

In early October, ERCOT issued a request for proposals “to increase operating reserves, adding up to an additional 3,000 MW for the winter 2023-2024 peak load season.” The RFP identified “mothballed,” “seasonably mothballed,” and “decommissioned” generating resources, all fossil-fueled resources. The RFP entirely eschewed renewables and battery storage.

On Nov. 17, ERCOT cancelled the resource RFP, citing “limited response from the market, which included only a small 11.1 MW of potentially eligible capacity.” Putting a predictable gloss of the RFP’s failure, ERCOT CEO Pablo Vegas said, “ERCOT is not projecting emergency conditions this winter and expects to have adequate resources to meet demand.”

Texas Tribune commented, “ERCOT’s plan to entice companies to make more power available involved asking if they were willing to bring some shuttered gas- and coal-fired power plants back online — and, if so, what it would cost ERCOT.

“As it happened, not a single company thought reviving an old power plant made sense, and the Nov. 6 deadline passed without a single proposal to revive a power source for the winter.

“ERCOT also offered to pay companies willing to lower their power use for up to six hours when needed, a concept industry observers generally say could help. That attracted three offers, but the showing was so poor that ERCOT scrapped the whole idea.”

Even before ERCOT’s failure became public, the RFP provoked a strong protest from the PUCT. Commissioner Will McAdams on Nov. 1 issued a scathing memo on the ERCOT auction, accusing the grid exceeding its authority by creating an unbudgeted short-term capacity market. Among the issues he raised:

  • “Does ERCOT have the authority to create a capacity market and procure that capacity in a two-month window without Commission or ERCOT Board oversight and guidance?
  • “Should the short-term capacity market have a budget and cost cap?
  • “Is the chance of ‘energy emergency alert’ above 10% the right standard for triggering a capacity market?”

ERCOT’s antipathy toward battery resources as a contributor to reliability has also played out during the controversy over the failed RFP. On Oct. 17, ERCOT issued a policy defining what is acceptable performance by battery electric storage systems, which ERCOT calls the “state of charge,” or SOC. According to the proposed policy, “As of June 1, 2023 there were approximately 3,300 MW of batteries energized on the ERCOT System.” ERCOT predicts battery capacity could be “9,500 MW” by October 2024.

The ERCOT proposal on batteries would establish strict operating rules, with fines of up to $25,000 per violation.

The PUCT must approve the ERCOT plan. Last Thursday (Nov. 30), the PUCT delayed action on the grid’s battery performance criteria, reflecting considerable resistance. Chief among the critics of ERCOT’s battery rules was Commissioner Jimmy Glotfelty. In a memo to the four other commissioners, he wrote that the ERCOT proposal reflects a bias against battery storage and discriminates against the technology compared to fossil generation.

Glotfelty accused ERCOT of “trying to make batteries look like and act like coal plants. ERCOT is pushing this purely because the current ERCOT systems do not accurately capture the operational flexibility and geographic diversity of storage resources.” Glotfelty noted. “Evidence on the September 6th [excessive heat] event and throughout the past summer show that batteries are making the system MORE reliable, especially on days when forced thermal outages are high and unexpected.”

He said that “it would be discriminatory to adopt burdensome operational requirements on storage devices when no such requirements are placed upon thermal plants.” He said the ERCOT proposal “is increasing the non-compliance penalties on batteries relative to other resources because the other resources are only penalized AFTER they fail to deliver as committed, but the SOC provisions would penalize preemptively BEFORE any actual failure to deliver.”

The PUCT may take up the ERCOT battery performance proposed rule at the Dec. 14 meeting.

–Kennedy Maize

kenmaize@gmail.com

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