The recent ERCOT workshop on NOGRR245 provided important clarification on several key issues regarding ride-through capabilities, exemption and extension requests, and modeling requirements. Below is a summary of the remaining discussion and answers provided during the meeting. For more information on NOGRR245, review the previous workshop summary here.
ERCOT NOGRR 245 Workshop II: Key Points
Exemptions and Extensions for NOGRR245: Questions regarding the difference between filing for an exemption and an extension were raised. If a resource cannot meet the requirement and seeks an exemption, they must submit a reason, such as a letter explaining why it cannot be met. However, when filing for an extension, it was noted that the requirement still must be met; they just need additional time. ERCOT staff explained that if an extension request is related to something involving the OEM (e.g., waiting for documentation or equipment), the OEM could provide supporting information. If the extension is due to scheduling or contractor delays, a detailed explanation would suffice.
Potential Penalties for Non-Compliance: Another question raised was whether there would be penalties if a resource’s settings are found to not be at maximum capability after a few years, particularly if the contractor did not set the maximum potential. ERCOT clarified that ERCOT does not impose penalties; instead, they work with resources to ensure settings are maximized. If a resource fails to meet the requirements, it will be given an opportunity to adjust settings without being referred to the Public Utility Commission (PUC) for non-compliance.
Simulations and Studies for NOGRR245 Submissions: A participant asked whether ERCOT requires simulation studies to comply with NOGRR245. The response was that ERCOT does not require specific simulations but encourages market participants to run simulations for their own confidence in meeting maximization requirements. While ERCOT does not mandate tests for specific capabilities, participants must ensure their resources meet the necessary performance standards outlined in the operating guides.
Information Requested in DocuSign Forms: There were concerns about certain questions in the DocuSign form that went beyond the information required by the operating guides. ERCOT acknowledged that while some information in the DocuSign form may seem beyond the operating guide’s requirements, the questions were included because ERCOT staff, in consultation with engineers, believed the data was necessary to perform their duties effectively. ERCOT emphasized that for any missing or incomplete data, participants should prioritize submitting required information and notify ERCOT if some questions could not be answered by the April 1 deadline.
Extension and Exemption Deadlines: ERCOT further clarified that the April 1 deadline for submitting exemption or extension requests is firm, as stipulated by the operating guides. However, if the request pertains to information not required by the operating guides, ERCOT would not enforce the deadline strictly and would allow additional time. ERCOT also emphasized the importance of providing the most accurate information available by the deadline, even if the full details are not yet available due to OEM delays.
Resources with Modified Interconnection Agreements: The workshop discussed how resources with amended interconnection agreements after August 1, 2024, should comply with NOGRR245. The response was clear: the original interconnection agreement date determines the applicable requirements for ride-through performance, even if the agreement is later amended.
Role of OEM Documentation in Maximization: If an OEM states that software updates will be released to improve equipment’s ride-through capability but cannot provide the details before the April 1, 2025, deadline, resources should provide the best available information by the deadline and supplement it as soon as the updates are received. ERCOT staff will consider these updates when determining whether to grant an extension or exemption.
Modeling Requirements and Updates: In response to questions about when model updates must be submitted, ERCOT clarified that if a resource’s model already reflects maximized capabilities, restudies may not be necessary. However, any updates to models after October 1, 2024, must include model quality tests as per ERCOT’s guidelines. Model updates are required to accurately represent the resource’s performance to ensure compliance with NOGRR245.
Simulation Scenarios for Solar + Battery Storage Projects: There was a question about whether specific scenarios must be run for solar plus battery storage projects to demonstrate compliance. ERCOT confirmed that all operating scenarios for such projects must be modeled and submitted, including maximum power injection and withdrawal scenarios, as outlined in the Dynamic Working Group (DWG) procedure manual.
Reporting and Attestation: For the submission of capability and performance reports, ERCOT does not require a simulation to demonstrate compliance with every requirement. Participants may submit an attestation of their resource’s capability to meet ride-through system disturbances to the maximum extent the equipment allows. However, accurate models and reports must be provided, and any discrepancies between the as-built model and field settings must be addressed in the documentation.
This workshop provided important clarifications on the process and requirements for NOGRR245 submissions. While the deadline for exemption and extension requests remains April 1, 2025, ERCOT staff emphasized collaboration and communication between market participants and ERCOT to ensure compliance. For questions, participants are encouraged to reach out to ERCOT’s NOGRR245 inbox for further guidance.
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