ERCOT Board Action
PRR Number / 523PRR / PRR Title / Revisions to Protocol Section 21Protocol Section(s) Requiring Revision (include Section No. and Title) / Section 21, Process for Protocol Revision
Proposed Effective Date / November 1, 2004
Priority & Rank Assigned / Not Applicable
Revision Description / This PRR modifies the process for revising the Protocols, including: establishing timelines for ERCOT to complete Impact Analyses for all PRRs submitted,standardizing certain provisions, correcting grammatical errors; and formalizing the process for submitting and approving System Change Requests.
Benefit / To address some concerns and make improvements to the process for revising the Protocols.
PRS Recommendation / PRS recommended approval of PRR523 as revised by Austin Energy, ERCOT, CenterPoint, TXU, and PRS.
TAC Recommendation / TAC recommends approval of PRR523 as recommended by PRS.
Board Action / Board approves PRR523 as recommended by TAC.
Sponsor
Name / Cheryl Moseley
E-mail Address /
Company / ERCOT
Company Address / 7620 Metro Center Dr., Met Ctr., Austin, TX 78744
Phone Number / (512) 225-7057
Fax Number / (512) 225-7020
Proposed Protocol Language Revision
21Process for Protocol Revision
21.1Introduction
(1)A request to make additions, edits, deletions, revisions, or clarifications to these Protocols, including any attachments and exhibits to these Protocols, is called a “Protocol Revision Request” (PRR). Except as specifically provided in other Sections of these Protocols, this Section shall be followed for all PRRs. ERCOT Members, Market Participants, PUCT Staff, and ERCOT staff Staff and any other Entities, are required to utilize the process described herein prior to requesting, through the PUCT or other Governmental Authority, that ERCOT make a change to these Protocols, except for good cause shown to the PUCT or other Governmental Authority.
(2)If a rule or order from the PUCT requires a change to these Protocols, the PUCT Market Oversight Division should initiate the Revision Request with regard to such rule or order.
If a rule or order from a Governmental Authority, other than the PUCT, requires a change to these Protocols, ERCOT staff shall initiate the Revision Request with regard to such rule or order.
All decisions of the Protocol Revisions Subcommittee (PRS), as defined below, the ERCOT Technical Advisory Committee (TAC) and the ERCOT Board with respect to any PRRevision Request shall be posted to the MISarket Information System within twothree (23) Business Days of the date of the decision. All such postings shall be maintained on the MISarket Information System for at least one hundred eighty(180) days from the date of posting.
The “next regularly scheduled meeting” of the Protocol Revision Subcommittee, TAC or the ERCOT Board shall mean the next regularly scheduled meeting for which required notice can be timely given regarding the item(s) to be addressed, as specified in the appropriate Board or committee procedures.
In regard to compliance with P.U.C.T Subst. R. 25.501, Wholesale Market Design in ERCOT, Section 21, Process for Protocol Revision, shall not apply. Proposed Protocols for compliance with that P.U.CT RuleSubst. R 25.501 shall be developed by the Texas Nodal team inutilizing the process approved by the ERCOT Board and subsequently submitted forto the PUCT for approval foras amendmentan amendment to these Protocols.
21.2Requests forSubmission of a Protocol Revision Request
The following Entities may requestsubmit a PRRevision Request:
(1)Any Market Participant;
(2)Any Entity that is an ERCOT Member;
(3)The Market Oversight Division of the PUCT staffStaff;
(4)ERCOT staffStaff; and
(5)Any other Entity that meets the following qualifications:
(a)Entity must reside (or represent residents) in Texas or operate in the Texas electricity market, and
(b)Entity must demonstrate that Entity (or those it represents) is affected by the Customer Registration or REC Program Sections of these Protocols.
Further Requirements for Revision Requests:
All Revision Requests must include a detailed explanation of how the Protocols language that requestor wishes to change (“Identified Language”) affects the requestor.
A Revision Request should be made in a timely manner, whenever possible, within ninety (90) days of the date the requestor has knowledge of the effect of the Identified Language with respect to the requestor.
21.3Protocol Revisions Subcommittee
TAC shall assign a subcommittee ("Protocol Revisions Subcommittee" or “PRS”) to review and recommend action on formally submittedPRRsevision Requests. TAC may create such a subcommittee or assign the responsibility to an existing subcommittee, provided that:
(1) such subcommittee’s meetings are open to ERCOT staffStaff, ERCOT Members, Market Participants, and the PUCT Market Oversight DivisionStaff;
(2) each Market Segment is allowed to participate,; and
(3) each Market Segment has equal voting power.
Where additional expertise is needed, the PRS may refer a PRR assign responsibility for review of and drafting in response to Revision Requests to working groups or task forces subcommittees that it creates or to existing subcommittees, working groups or task forces of TAC for review and comment on the PRR. Suggested modifications—or alternative modifications if a consensus recommendation is not achieved by a non-voting working group or task force— to the PRR should be submitted by the Chairchair or the Chair’schair’s designee on behalf of the subcommittee, working group or task force as comments on the PRR for consideration by PRS. However, the PRS shall retain ultimate responsibility for the processing of all PRRsevision Requests.
ERCOT shall consult with Tthe cChairchair of the PRS, or an ERCOT employee designated by the PRS, shall to coordinate and establish the meeting schedule for the PRS or other assigned subcommittee. The PRS shall meet at least once per month and shall ensure that reasonable advance notice of each meeting, including the meeting agenda, is posted to the MISarket Information System.
21.4Protocol Revision Procedure
21.4.1Review and Posting of Protocol Revision Requests
PRRsevision Requests shall be submitted electronically to ERCOT by completing the designated form provided on the MISarket Information System. ERCOT shall provide aAn electronic return receipt response shall be provided to the submitter upon receipt of the PRRevision Request.
The PRRevision Request shall also include, at least, the following information:
(1)Description of requested revision;
(2)Reason for the suggested change;
(3)Impacts and benefits of the suggested change on ERCOT market structure, ERCOT operations and Market Participants, to the extent that the submitter may know this information;
(4)AnPRR Impact Analysis (PIA)(applicable only for a PRR submitted by ERCOT staffStaff)
(4)(5)List of affected Protocols Sections and subsections;
(5)(6)General administrative information (organization, contact name, etc.); and
(6)(7)Suggested language for requested revision (optional).
ERCOT shall evaluate the PRRevision Request for completeness and shall notify the submitter, within five (5)three (3)five (5) Business Days of receipt, if the PRRevision Request is incomplete, including the reasons for such status. ERCOT may provide information to the submitter that will correct the PRR and render it complete. An incomplete PRRevision Request shall not receive further consideration until it is completed. In order to pursue the revision requested, a submitter must submit a completed version of the PRRnew Revision Request with the deficiencies corrected.
Posting of the Revision Request
If a submitted PRRevision Request is complete or once a PRR is corrected, then, within five (5) Business Days of receipt, ERCOT shall post the a complete PRRevision Request to the MISarket Information System and distribute the PRRevision Request to the PRS within three (3) Business Days.
21.4.2Withdrawal of a Protocol Revision Request
Upon notice to the PRS, the submitter of a PRR may withdraw the PRR at any time prior to approvalreviewapproval of the PRR by the PRS. ERCOT shall post a notice of the submitter’s withdrawal of a PRR on the MIS within three (3)one (1) Business Days of the submitter’s notice to PRS.
The submitter of a PRR may request withdrawal of a PRR after its approval by PRS. Such withdrawal must be approved by the TAC (if it has not yet been considered by TAC) or by the Board (if it has been recommended for Board approval by TAC but not yet considered by the Board).
Once approved by the Board a PRR cannot be withdrawn.
21.4.3Protocol Revision Subcommittee Review and Action
Any interested ERCOT Member, Market Participant, the PUCT Market Oversight DivisionStaff, or ERCOT may comment on the PRRevision Request.
To receive consideration, comments must be delivered electronically to the PRS and ERCOT in the designated format provided on the MISarket Information System within twenty-one (21) days from the posting date of posting/distribution of the PRRevision Request. Comments submitted after the due date of the twenty-one (21) day comment period may be considered at the discretion of PRS after these comments have been posted. Comments submitted in accordance with the instructions on the MIS—regardless of date of submission— shall be posted to the MIS and distributed electronically to the PRS within three (3) Business Days of submittal.
(1)At any time, the submitter may notify PRS that the Revision Request is no longer desired, and the PRS, at its sole discretion, may elect to terminate the consideration of the Revision Request and shall post, within two (2) Business Days of election to terminate, a notice to that effect on the Market Information System.
The PRS shall review the PRRevision Request within thirty-five (35) days of posting the Revision Request at its next regularly scheduled meeting after the end of the twenty-one (21) day comment period, unless the twenty-one (21) day comment period ends less than seven (7)three (3) Business dDays prior to the next regularly scheduled PRS meeting. In that case, the PRR will be reviewed at the following month’s regularly scheduled PRS meeting. At such meeting, the PRS may take action on the PRR to 1) recommend approval, as submitted or modified, or 2) rejection, or 3) defer action on the PRR or 4) refer the PRR to a subcommittee subcommittee,or workgroup, or task force as provided in Section 21.3, Protocol Revision Subcommittee.
Within forty-fivethree (453) Business dDays after PRS takes action to approve, approve with modificationsmodify, defer, or reject onposting of the PRRevision Request, the PRSERCOT shall submitissue a report (“RevisionPRS Recommendation Report”) to TAC reflecting the PRS action and post the same to the MISarket Information System. The RevisionPRS Recommendation Report shall contain the following items:
(1)Identification of submitter;
(2)Submitter’s suggested language, if any, in the Revision Request;
(3)(2)Modified ProtocolAlternate language, if any, proposed by the PRS;
(4)(3)Identification of authorship of comments and evaluation of such comments received;
(5)Comparative evaluation of Revision Request to other Independent System Operators’ business practices or operating policies;
(4)Proposed effective date(s) of the PRRany revisions; and
(6)(5)Priority and rank for any PRRs requiring a system change project; and
(7)(6)Recommended action: (e.g., acceptanceapproval, rejection, deferral, or useapprovalofwithalternatemodified language).
The PRS Chair shall notify TAC of PRRs rejected by PRS.
The PRS Chairchair shall notify TAC of PRRs recommended by PRS for rejection.
21.4.4Comments to the RevisionProtocol Revision Subcommittee Recommendation Report
Any interested ERCOT Member, Market Participant, PUCT Market Oversight DivisionStaff or ERCOT staffStaff may comment on the RevisionPRS Recommendation Report. To receive consideration, comments on the PRS Recommendation Report must be delivered electronically to the TAC and ERCOT in the designated format provided on the MIS within twenty-one (21) days from the date of posting/distribution of the PRS Recommendation Report. Comments submitted after the due date of the twenty-one (21) day comment period may be considered at the discretion of TAC. To receive consideration, comments must be delivered electronically to ERCOT within twenty-one (21) days from the date of posting of the RevisionPRS Recommendation Report by completing and submitting the comment form provided on the MIS.
Within three (3) Business Days of receipt of comments related to the PRS Recommendation Report, ERCOT shall, within two (2) Business Days of receipt, post to the Market Information System allsuch comments to the MIS.timely delivered The comments shall includeing identification of the commenting Entity., and forward such comments to TAC.
To receive consideration, comments on the PRS Recommendation Report must be delivered electronically to the TAC in the designated format provided on the MIS within twenty-one (21) days from the date of posting/distribution of the PRS Recommendation Report. Comments submitted after the due date of the twenty-one (21) day comment period may be considered at the discretion of TAC. Comments submitted in accordance with the instructions on the MIS—regardless of date of submission—shall be posted to the MIS and distributed electronically to the TAC and PRS within three (3) Business Days of submittal. If comments on the PRS Recommendation Report are timely filed and posted within three (3) Business Days of the date that the PRR is scheduled to be discussed at a regularly scheduled TAC meeting, then TAC shall defer consideration of the PRR until its next regularly scheduled meeting.
The TAC shall review the PRR Recommendation Report and any posted comments to the Report at its next regulatory regularly scheduled meeting after the end of the twenty-one (21) day comment period, unless the twenty-one (21) day comment period ends less than seven (7) days prior to the next regulatory regularly scheduled TAC meeting. In that case, the PRR will be reviewed at the following month’s regulatory regularly scheduled PRSTAC meeting.
21.4.5Protocol Revision Request Impact Analysis
ERCOT shall submit an initial PRR Impact Analysis (PIA) with any PRR ERCOT submits to the PRS based on the original language in the PRR. The initial PIA will provide PRS with guidance as to what computer systems, operations, or business functions could be affected by the PRR as submitted.
The PIA should assess the impact of the proposed PRR on ERCOT computer systems, operations, or business functions and shall contain the following information:
(1)an estimate of any cost and budgetary impacts to ERCOT for both implementation and on-going operationsal impacts;
(2)the estimated amount of time required to implement the revised Protocol language;
(3)the identification of alternatives to the original proposed language that may result in more efficient implementation;
(4)the identification of any manual workarounds that may be used as an interim solution and estimated costs of the workaround; and
(5)verification of review (if necessary) of the PRR by the Credit Working Group and the impact of its review on the PRRPIA.
Upon receipt of a PRR submitted by any Entity other than ERCOT, ERCOT shall perform an initial evaluation of the impact on ERCOT and include the evaluation in ERCOT’s comments. The initial evaluation will provide PRS with guidance as to what computer systems, operations, or business functions could be affected by the PRR as submitted. ERCOT shall post its comments prior to the PRS initial review of the PRR, if practicable.
After the PRS’s initial review and recommendation of approval of a PRR, and the issuance and posting of the PRS Recommendation Report, ERCOT shall initiate prepare an “Impact Analysis” PIA based on the PRS Recommendation Report to identify and evaluate the required changes to the ERCOT systems and staffing needs, including, but not limited to, ERCOT’s operating systems, settlement systems, business functions, operating practices, and ERCOT System operations, and staffing needs. If ERCOT has already prepared a PIA, then ERCOT shall instead update the existing PIA, if needed, to accommodate the PRS Recommendation Report.. The Impact Analysis shall include:
(a)an estimate of any cost and budgetary impacts to ERCOT for both implementation and on-going operations impacts;
(b)the estimated amount of time required to implement the revised Protocol language;
(c)the identification of alternatives to the original proposed language that may result in more efficient implementation; and,
(d)the identification of any manual workarounds that may be used as an interim solution and estimated costs of the workaround; and.
(e)indication of whether there are credit implications to the market, whether the Credit Working Group has reviewed the PRR, and the outcome of its review.
Unless a longer review period is warranted due to the complexity of the proposed Protocol revisions as indicated in the PRSPRRS Recommendation Report, ERCOT shall issue the PIA for the recommended PRR within twenty-fivethirty (3025) days after PRS approval of the PRR. ERCOT shall post the results of the completed PIA on the MIS. The PRS may alter the timeline for review of the PRR while processing PRRs conducting the Impact Analysis in Section 21, Process for Protocol Revision, but only to the minimum extent necessary in order to allow ERCOT to complete its accommodate the analysis in a timely manner. Unless a longer period is warranted due to the complexity of the change, ERCOT shall initiate the Impact Analysis when the PRR is posted and provide available information to PRS, TAC, and the Board.If a longer review period is required for ERCOT staffStaff to complete a full PIA, ERCOT staffStaff shall submit a schedule for completion of the PIA to the PRS chair.