ERCOT’s third NOGRR245 workshop doubled as a reality check and a how-to. The grid is still seeing frequent inverter-based resource (IBR) ride-through events; 2024 logged ~7–8 events and 2025 is already ~12 through July. ERCOT walked through what went wrong with April’s filings, what a compliant resubmittal must contain by Sept. 15, 2025, and answered granular questions on signatures, notarization, DocuSign logistics, models, schedules, and the edge cases everyone’s worried about.
Below is the full story, context, decisions, and clarifications.
NOGRR245: Why this is happening
- The problem persists. IBR ride-through disturbances continue across the fleet. ERCOT needs plant-specific, POI-based capabilities and models it can actually study.
- The rule is in force. NOGRR245 took effect Oct 1, 2024. Required data due Apr 1, 2025 (extended to Apr 15).
- April didn’t cut it. Out of 795 resources contacted, 429 asked for an extension and/or exemption. None of the April packages met all requirements; ~54 resources submitted models.
What changes now, and what doesn’t
- Sept. 15, 2025 is not a fresh chance to start. It’s a second bite at the supporting information only for entities that already requested an extension or filed a notice of intent to seek exemption in April.
- Submission channel: ERCOT is moving back to DocuSign (not email). Templates for the two capability reports and a new exemption form will be posted on the Resource Integration site; fill them and attach through DocuSign.
- Model review hasn’t changed. Anything that affects dynamic behavior still goes through PGRR109 with Model Quality Tests (Planning Guide §6.2; DWG Manual). NOGRR245 requires you to submit the model by Sept. 15; it does not require ERCOT approval by that date.
Exactly what ERCOT wants on Sept. 15
1) Two resource-level capability reports (frequency & voltage)
Use ERCOT’s templates (one packet per resource). Key items:
- D — Name the exact subsections you can’t meet (e.g., “2.6.2.1(3)” or “2.11.2(6)”). No paraphrasing parent sections.
- E (current) & J (post-max) capability tables/curves at the POI, 0–600s, with a clear legend. No “999/888/XXX” placeholders.
- Exemption case: If you cannot change anything, J may match E, but say so explicitly in the text and re-attach the curve.
- F/G — Technical limitations, with proof. Provide a detailed narrative and a signed letter verifying the limitation from either:
- the OEM (signed by an officer/executive with binding authority), or
- an engineering firm (signed by an officer/executive).
If you cannot get a letter that covers the entire plant, include G(i) a notarized attestation from your highest-ranking representative/officer with binding authority (see “Signatures & notarization,” below).
- H — Software/firmware settings you’ll change (be concrete: version numbers/features, e.g., PPC v2.11→v3.4; enabling filtering/anti-islanding behaviors).
- I — Non-software modifications (e.g., relay ranges, UPS replacement to avoid unintended cessation). “None” is acceptable if truly none.
- K — Schedule with milestones. Use dates or quarters and list major steps (OEM engineering, field changes, studies). You may note dependencies/backlogs; a single end date alone is not enough.
- L — Models. Submit PSSE and PSCAD representing expected post-max performance and all limitations. Reference your RIOO/RCR ID and submission date.
- If seeking exemption and nothing can change: explicitly state the current model is final and already reflects all limitations.
- M — What you can’t model. Describe any limitation/behavior that cannot be accurately represented in the model (e.g., specific phase-jump responses).
2) If you intend to seek an exemption now
Only for resources that filed a notice of intent to seek exemption in April:
- Fill the new exemption form and attach it in DocuSign.
- Form must be signed by the Authorized Rep (AR) or Backup AR (BAR).
- ERCOT will cross-check that your request matches the April notice; new exemption topics won’t be accepted.
Signatures & notarization clarified
- Who can sign an OEM/engineering letter? An officer/executive with authority to bind the company. It does not need to be the corporate CEO; ERCOT will accept any signer who can bind the corporation. A technician cannot.
- Who signs the G(i) attestation? The resource entity’s highest-ranking representative or officer with binding authority for that entity (often the president of the project LLC, not the parent-company CEO). This attestation must be notarized.
- Does the OEM/engineering letter need notarization? No. It must be signed by an officer/executive; notarization applies to the G(i) attestation.
DocuSign mechanics
- Who receives DocuSign? Only resources that asked for an extension or filed a notice of intent to seek exemption in April.
- Field behavior: Items G and G(i) will have both text and attachment fields. If G(i) doesn’t apply (you have a signed OEM/engineering letter that fully covers the plant), type “Not applicable” and leave the attachment empty.
- Attach the exemption form (if applicable) and ensure the AR/BAR signs it.
Modeling & PGRR109: what to submit and how to route it
- By Sept. 15: Submit PSSE + PSCAD models that match your post-max limits (or state your existing model is final).
- Submission path: Use RIOO-RS. Email [email protected] and state it’s a NOGRR245 submission; include the RIOO/RCR ID, what changed, and the MQT package per Planning Guide §6.2 and DWG Manual §3.1.5.
- Review timing: ERCOT review is 10 business days, extendable +20; if TSP stability checks are needed, they may take up to ~90 days. Worst-case lead time can stretch 4–5 months, so don’t wait until October.
- Balance-of-plant (BOP) modeling: Submit the model required by the Operating Guides. If a limitation can’t be modeled, describe it under M.
Schedules and updates
- Granularity: Provide steps/milestones and target dates/quarters; note dependencies (e.g., OEM backlogs).
- Updating schedules: Not required by rule, but ERCOT appreciates updates if plans slip—send them to [email protected].
Extensions vs. exemptions: process & limits
- Extension filings (you can comply, need more time): If your Sept. 15 package is incomplete, ERCOT will send a deficiency notice and give 10 business days to cure (Operating Guide 12.2.1.3(1)).
- Latest permissible extension end date: Dec 31, 2027.
- Exemption filings (you cannot comply): If incomplete on Sept. 15, exemptions will likely be denied. Appeals go to the PUC; timing is unknown, and there is no cure period in the rule.
- Switching tracks: If you filed an exemption in April but now believe you can comply with time, you may convert to an extension by Sept. 15. The reverse (adding a new exemption now) is not allowed.
- If you didn’t request anything in April and can’t comply: ERCOT would not speculate on the operational path during the workshop. In general, ERCOT retains authority to act if a reliability risk emerges; some participants suggested operational planning might include an NOSO, but ERCOT did not offer a blanket directive.
IEEE 2800, legacy fleets, and ongoing updates
- Post-Aug 1, 2024 SGIAs: IEEE 2800 compliance is mandatory; no exemptions.
- Legacy units: The rule requires you to maximize ride-through to the greatest extent possible; April IEEE 2800 data were often weak. ERCOT emphasized maximization is a compliance requirement.
- RIOO is being upgraded to capture and maintain FRT/VRT & IEEE 2800 data across the entire lifecycle (initiation attestation, QSA, sync, pre-COD, and ongoing operations via a dedicated write-through change-request type).
- ERCOT will not approve Part 2/Part 3 checklists without current data or confirmation that data are unchanged.
- Expect an annual touchpoint from ERCOT to confirm your data remain accurate.
- Target go-live: Q4 2025.
Versioning: PSS®E 35 vs 36
- For Sept. 15 NOGRR245 submissions, ERCOT expects PSS®E v35 (per current process).
- The separate transition to PSS®E v36 (TWG/market notice) is due June 2026; during the transition ERCOT may require models in both 35 and 36 for case development, but v36 is not required for Sept. 15.
Do’s and Don’t’s for NOGRR245
Do
- File one DocuSign packet per resource using ERCOT’s templates.
- Cite exact subsections you can’t meet; provide POI-based curves for current and post-max.
- Attach a signed OEM/engineering letter verifying limitations; if full-plant coverage is impossible, attach the notarized G(i) attestation from your highest-ranking binding officer.
- List specific software/firmware and hardware/BOP changes and a milestoned schedule.
- Submit PSSE + PSCAD (or declare the current model final), with RIOO/RCR IDs and an MQT package, and email [email protected].
Don’t
- Don’t submit fleet-level packets, custom templates, generic claims (“we can’t meet the curve”), or curves full of placeholders.
- Don’t treat Sept. 15 as a chance to add new exemptions or new resources that didn’t file in April.
- Don’t provide only an end date as a “schedule.”
The bottom line
You’ve got one shot to make Sept. 15 count. ZEG helps resource owners translate ERCOT’s guidance into a complete, defensible submission, fast.
How ZEG helps
- ERCOT Guide & Rule Alignment: Interpret ERCOT Operating Guides and PUCT rules and build practical compliance roadmaps for NOGRR245 filings.
- Dynamic Modeling & Validation: Develop/refresh PSS®E and PSCAD models and support post-commissioning model validation to reflect expected performance at the POI.
- Electrical & Stability Studies: Execute the studies that underpin credible ride-through capability (load flow, transient stability, harmonic/volt-var, etc.).
- Exemption/Extension Packages: Prepare technically sound exemption or extension requests and navigate regulatory communications with ERCOT.
- OEM & Engineering Coordination: Coordinate with OEMs/engineering teams to secure the technical inputs models and packages depend on.
- ERCOT Submission Support: Compile and submit ERCOT-required materials (forms, models, supporting studies) as part of ISO/RTO registration, energization, and commissioning workflows.
- Quality & Completeness Checks: Apply technical due diligence so your packet lands complete and defensible the first time.
Let our experts shoulder the heavy lift. We will outline a tailored plan and get your packet moving. Contact us today.
Learn more about NOGRR245, PGRR109, IEEE2800, or view NOGRR245 Workshop III meeting materials.
