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PUCT Staff Outlines Circumstances in Which Energy Storage Resources Should be Allowed to Participate in Dispatchable Reliability Reserve Service
In a Staff Memo, Commission Staff of the Texas Public Utility Commission (PUC) “requests that the Commission provide guidance to ERCOT market participants regarding the circumstances under which energy storage resources (ESRs) may participate in Dispatchable Reliability Reserve Service (DRRS).”
In its memo “Staff recommends that the Commission consider providing the following guidance to stakeholders regarding ESR participation in DRRS:
- Stakeholders should continue to develop DRRS without attempting to include ESRs to avoid delaying the implementation of the core DRRS functionality in NPRR 1309.
- ESR participation in DRRS should be considered independently of both NPRR 1309 and NPRR 1310.
- To the extent ESR participation is permitted in DRRS, it should be limited to resources with sufficient storage capacity (MWh) to discharge at their maximum sustained discharging capability (MW) for at least four hours (e.g., four-hour ESRs).
- The requirements of PURA § 39.159(d)(2)(A) and (B) should be considered a joint requirement. Specifically, a resource qualifies to provide off-line DRRS up to the power output (MW) it can reach within two hours of being called on for deployment.
- The duration requirement for DRR S should be kept at four hours for now and not increased yet as allowed by statute.”
As background, “[o]n November 20,2025, ERCOT submitted NPRRs 1309 and 1310 to begin implementing DRRS pursuant to PURA § 39.159(d). On February 27,2026, ERCOT solicited input from stakeholders concerning ESR participation in the provision of DRRS.1 On March 9,2026, the ERCOT Technical Advisory Committee (TAC) hosted DRRS Workshop #3, during which stakeholders discussed the topic of ESR participation in DRRS.2 Based on its monitoring of the stakeholder process, Staff respectfully submits that stakeholders would benefit from Commission guidance regarding policy decisions concerning ESR participation at this time. Such guidance would focus ERCOT staff and stakeholder resources on developing a revision request which may align with the Commission’s stated policy preferences.”
