Last week, ERCOT gathered stakeholders to address common issues from April’s NOGRR245 data submissions and prepare market participants for the final resubmission deadline on September 15, 2025. The workshop commenced by recognizing the considerable efforts resource entities are undertaking to comply with the NOGRR245 requirements. Participants were encouraged to actively engage throughout the session to clarify evolving technical nuances and procedural updates, reflecting the complex and dynamic nature of grid interconnection compliance.
Model Compliance Updates and Review Processes
A core focus was the detailed explanation of the PGRR109 model database review process, which serves as a critical checkpoint to maintain alignment and consistency between the models used in studies and those employed in real-time operations. This process supports ERCOT’s goal of ensuring that dynamic performance representations are accurate and reliable.
- Modification Classification:
- Major Modifications: Significant changes such as increasing inverter capacity, changing turbine equipment, or any alteration that materially impacts unit behavior require re-entry into the full generation interconnection process, including comprehensive studies and approvals.
- Minor Modifications: Adjustments such as tuning control settings or small parameter changes may be eligible for a streamlined review pathway under the PGRR109 process, allowing quicker turnaround while maintaining compliance rigor.
- Submission Protocols:
Submissions must be sent exclusively to a dedicated email inbox to ensure proper routing and processing. Requests must include comprehensive documentation such as updated dynamic models, Model Quality Test (MQT) packages, and simulation files. Submitters are advised to reference Planning Guide sections 5.4, 5.5, and 5.2.1.1 to ensure completeness and adherence to prescribed formats. Properly formatted subject lines and detailed descriptions of the modifications are essential to minimize review delays.
- Review Timelines:
Standard reviews typically require around ten business days; however, review durations can extend based on workload, complexity, and the nature of changes. Major modifications or substantial parameter changes may trigger Transmission Service Provider (TSP) requested limited dynamic stability studies, which can extend the review process to as much as ninety days. Stakeholders were urged to plan submissions early to accommodate these lead times.
Modeling Scope and Technical Requirements
Clarifications were made regarding what must be included in the dynamic models submitted:
- Models must comprehensively incorporate all technical limitations and protection settings that influence dynamic performance at the Point of Interconnection (POI).
- Even if certain balance of plant protection settings do not directly affect inverter capabilities or dynamic responses, they are required to be documented in the model to maintain transparency and completeness.
- If any technical limitation or protection setting cannot be explicitly modeled, entities must clearly state these limitations within their submissions, explaining the nature of the unmodelable aspects.
This clarity helps prevent ambiguity and aligns expectations across ERCOT, TSPs, and resource entities.
Ongoing Data Maintenance and RIOO System Enhancements
ERCOT outlined enhancements planned for the RIOO system to streamline the management and maintenance of ride-through capability data—specifically Frequency Ride Through (FRT), Voltage Ride Through (VRT), and IEEE 2800 data—across the entire lifecycle of a resource. Key highlights include:
- Lifecycle Data Milestones: Resource entities must provide updated data at critical lifecycle points including project initiation, Qualified Scheduling Entity Authorization (QSA), production load date, synchronization, and commercial operation.
- Write-Through Change Request Type: To simplify ongoing updates related specifically to ride-through data without requiring full model resubmissions, ERCOT will introduce a dedicated “write-through” change request type. This will enable more efficient data management for ongoing operational changes.
- Implementation Timeline: The system upgrade is targeted for Q4 2025 rollout, with ERCOT committing to annual outreach efforts to resource owners to verify and update ride-through data, thereby ensuring continued data accuracy and reliability.
Compliance Challenges and Key Talking Points
Significant discussion centered on real-world challenges and compliance expectations:
- Technical and Logistical Constraints: Resource entities face obstacles including limited support from Original Equipment Manufacturers (OEMs), incomplete or poor-quality data—especially for legacy units—and complex technical demands. These challenges contribute to difficulties in submitting timely and fully compliant data packages.
- Necessity for Accurate Data Submission: ERCOT emphasized that compliance hinges on submitting precise, comprehensive, and operationally aligned data. Accurate submissions are critical for ERCOT and TSPs to perform reliability assessments that protect grid stability and meet regulatory requirements.
- Deadline Extension Announcement: In light of ongoing challenges and stakeholder feedback, ERCOT announced an extension for submission deadlines to September 15. This extension aims to provide additional time for resource entities to finalize and submit required data and models while maintaining rigorous compliance standards.
Model Version Submissions and Transition Planning
ERCOT addressed the phased transition between PSS/E software versions for model submissions:
- Resource entities must submit models in both PSS/E versions 35 and 36 during the transition period.
- For NOGRR245 compliance, PSS/E version 35 submissions are required by September 2025.
- PSS/E version 36 submissions will be due for other case developments by June 2026.
- Entities are encouraged to plan resource allocation accordingly to avoid duplication of effort and ensure timely compliance.
Extension Policies and Deadline Management
ERCOT clarified policies surrounding compliance deadline extensions:
- Extensions may be granted up to a final hard deadline of December 31, 2027, beyond which no further extensions will be permitted.
- Resource entities are urged to communicate proactively with ERCOT if delays arise, facilitating better scheduling and minimizing last-minute compliance risks.
Q&A Highlights and Clarifications
During the Q&A, several important points were reinforced:
- Models must incorporate protection settings that truly reflect the technical and operational limitations of equipment, avoiding under-reporting or omission of critical data.
- Ongoing RIOO system updates will enhance data quality management for ride-through capabilities and simplify future compliance submissions.
- ERCOT recognizes the existing gaps in legacy data and is actively working to close those gaps through outreach and system improvements.
- The maximization of ride-through capability is a binding compliance requirement within NOGRR245, rather than an aspirational guideline, and non-compliance could lead to violations of operating standards.
- Clear distinction was made between requirements under NOGRR245 and broader IEEE 2800 data expectations, helping entities focus on applicable standards and avoid confusion.
Navigating NOGRR245
The workshop concluded with ERCOT acknowledging the substantial progress made by resource entities despite ongoing challenges. ERCOT reaffirmed its commitment to collaboration and transparency, encouraging continued engagement to navigate the technical complexities and ensure successful compliance. The proactive steps being taken, including system upgrades, outreach initiatives, and deadline accommodations, are intended to support resource entities in meeting obligations while maintaining grid reliability and operational excellence.
Navigating ERCOT’s NOGRR245 compliance requires deep expertise in grid interconnection standards, resource modeling, and regulatory processes. At ZEG, we specialize in guiding renewable and inverter-based resource developers through these complex requirements with tailored strategies, technical model development support, and compliance roadmaps.
If your project is affected by NOGRR245 or you want to ensure your ride-through capabilities and exemption/extension submissions meet ERCOT’s stringent criteria, reach out to Zero Emission Grid today.
Our team will help you:
- Interpret and comply with ERCOT’s operating guides and Public Utility Commission rules.
- Coordinate with OEMs and engineering teams to develop accurate PSSE and PSCAD models.
- Prepare comprehensive, technically sound exemption or extension requests.
- Navigate regulatory communications and feedback to meet critical deadlines like September 15.
Contact us now to safeguard your project’s compliance and contribute to a more reliable, cleaner Texas grid.
View Workshop Materials here.
