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Gon r I Number: 46369
Item Number: 47
Addenduni StartPage: 0
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SIERRA
PUBLIC UTILIT'Y CCMMISSION
F iLING CLERK
CLUB
FOUNDED 1892
Lone Star Chapter
PUC DOCKET NO. 46369
,-Rulemaking Related to
Reliability-Must-Run Service -Second Strawman
§
BEFORE THE
PUBLIC UTILITY COMMISSION
OF TEXAS •
FebruarY loth, 2017
REPLY COMMENTS FILED BY
LONE STAR CHAPTER OF SIERRA CLUB
Comes now the Lone Star Chapter of the Sierra Club to submit these reply comments
to the Rulemaking Relating to Reliability Must-Run Service -- Second Strawinan and
Request for Comment.
•
As mentioned in previous comments, the Sierra Club is supportive of the efforts of the
Commission to review the current rules (and protocols) for RMR units, and is general
support of the effort to both increase the notice requirement to ERCOT from 90 to 18o
days, to require that ERCOT consider both an RMR and an MRA concurrently, and to
the requirement that any RMR or MRA agreement be approved by the ERCOT Board
of Directors. We believe this will help put appropriate limits on the use of an MRA or .
RMR, which are out-of-market solutions as units retire. We are disappointed that the
second strawman returns to the 90-day limit and would urge the Commission to
consider a i8o-day requirement as is common in many ISOs. Thus, we agree with the
EnerNOC comment ,that "ERCOT šhould be given a tirneline that allows ERCOT
evaluate the MRA options before entering into an RMR contract."
We agree with the inajority of commentators, including EnerNOC, ERCOT, txelon,
Luminant and many others that the MRA resources should not be limited to only
demand-side and ERS resources. We believe there are a variety of resources that could
in theory provide a more cost-effective approach to keeping the lights on in the event
of an announced retirement, and traditional generation, demand-side resources,
storage and distributed generation resources , should all be eligible to participate. We
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do agree that some limits could be established to prevent generators from both
participating in the energy or ancillary service markets while alsO receiving payments'
for a MRA contract.
As ERCOT itself made clear in its comments, "ERCOT's July 2016 solicitation for MRA
proposals td replace the June 2016 RMR contract with NRG Texas Power LLC
demonstrates the feasibility of including both generation resources and load resources in
MRA procurement. Moreover, allowing broader participation in the procurement of MRA
would likely decrease the probability that the MRA procurement process might fail due to
an insu cient number of bids."
While we agree with Exelon and others and do not oppose a generator subject to RMR
service from providing MRA service (assuming.it is a different generation unit), we
would hope that such situations be Assessed by the ERCOT process and Board to avoid
market manipulations. We believe having the information being as transparent as
possible and requiring Board approval ultimately is the best way to prevent any
(( gaming" of the system.
We agree with TIEC comments and we do not expect windfall profits to occur from an
MRA given that an MRA should be more cost-effective than any RMR in order to be
chosen. In addition, our view is that any multi-year contract should be reviewed after
one year has occurred.
We believe the Centerpoint cornments which would add some additional information
if the ERCOT Board decides to reject an MRA or RMR agreement are reasonable given
the unlikely event that the Board rejects a staff recommendation. We also generally
agree with NRG -comments that "there is value in providing direction to ERCOT to work
with environmental regulators to structure althrnatives to retrofitting older generation units"
and we would be in support of that direction.
We do not support the suggestion of Luminant of actually eliminating the MRA
process as an alternative approach.
The Lone Star Chapter appreciates the opportunity to comment on the straWman in
PUC DOCKET NO. 46369 and file these reply comments. Again, we express our belief
that MRA and RMR resources should be assessed simultaneously and that the number
of days for providing notice be raised from 90 to i8o days.
Sincerely,
AF
Cyrus Reed, Conservation Director
Lone Star Chapter, Sierra Club
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