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In Texas parties file comments in the PUC’s net metering rulemaking.

Data Center Coalition – “The Data Center Coalition recommends the Commission adopt consistent requirements for large load arrangements as it pertains to curtailing during emergency operations. Net metering arrangements should not be viewed in a silo. Net metering arrangements are one of many commercial options for securing energy to operate a data center.”

“Before finalizing rules related to net metering and its emergency response provisions, several important details still need to be addressed. For instance, stakeholders would benefit from greater clarity on when large loads are generally expected to curtail, how net metering arrangements integrate into the broader framework of demand response during anticipated emergency events, and the potential unintended consequences of the proposed regulations.”

“Therefore, DCC recommends that the Commission initiate a dedicated rulemaking process focused specifically on emergency response as it relates to load curtailment during emergencies. To ensure consistency across projects, the Commission should consider consolidating emergency response provisions into a standalone rulemaking. This approach would offer stakeholders and the Commission a structured opportunity to examine and address the detailed aspects of emergency operations.”

ERCOT – A. Interpretation of” In Advance of an Anticipated Emergency Condition” 

“ERCOT’s initial comments proposed that the term “emergency condition” should be understood to include both a capacity emergency-i.e., an Energy Emergency Alert (]BEA)-and a transmission emergency, consistent with the meaning and application of the term “Emergency Condition” in the ERCOT Protocols and the ERCOT Operating Guide.1 Therefore, when PURA § 39.169(d) allows the Commission to impose a condition on a net metering arrangement requiring the generation resource to make its capacity available “in advance of an emergency condition,” that provision clearly contemplates a period befbre an EEA or transmission emergency.” A. Interpretation of”In Advance of an Anticipated Emergency Condition”

1. Interpretation of “Make Available”
   With respect to the statutory language requiring a dispatchable generator to “make” [itsl dispatchable capacity available” to the ERCOT power region following the implementation of the net metering arrangement, a number of commenters offered interpretations of that phrase that either align with or do not conflict with ERCOT’ s interpretation, which is that such capacity is made available to the ERCOT system by curtailing the co-located load so that the generation resource can export up to its full capacity to the grid as may be directed by ERCOT dispatch.”

Calpine – The Commission should interpret the “make available” requirement in a flexible manner, allowing a co-located generation resource to meet the obligation not only through reduction in the co-located load’ s demand, but through other means such as contracting with other dispatchable capacity or building additional new capacity in the same or greater amounts capable of dispatch. 

• This consideration should also inform the Commission’s consideration of ERCOT’s proposed large load curtailment program. SB 6 allows compliance by making other dispatchable capacity, while ERCOT would rely exclusively on physically curtailing large loads. The Commission should ensure other means as Calpine and others have listed will be acceptable to ensure compliance with generator obligations in emergency conditions, not only physical load curtailment. 

• The Commission should reject TPPA’s Initial Comments, which roundly oppose generation netting solutions recognized under NPRR 945 and now SB 6 as inconsistent with applicable law and outside the scope of this ruemaking proceeding. TPPA has the option to pursue its contentions in the ERCOT stakeholder process, but they are outside the scope of this rulemaking and SB 6.
• Calpine agrees with Oncor’ s recommendation to combine the proposed rule’ s Stranded Transmission Asset and Underutilized Transmission Asset definitions. o Calpine would modify the proposed combined definition to specify that only radial lines may qualify as such assets (as Oncor suggests), and also that such radial lines qualify as “stranded or underutilized” only if they are altogether “unused.” This latter modification eliminates the subjectivity in determining if a radial line is “effectively” unused, resulting in a more efficient application and also recognizing the value such radial lines can provide to the ERCOT system. 
• The Commission should impose a reasonable time period for TDSPs to complete Large Load Interconnection Studies, to avoid this portion of the overall net metering implementation process becoming a bottleneck that thwarts the Legislature’s goal of efficiently and timely providing large loads access to the grid and to locating readily available electric capacity.

Read all comments here.

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(PUCT Opened This Rulemaking To Develop The New 16 TAC §25.205 To Implement PURA 39.169.)