News Stories

Luminary Strategies Presents Speed to Power Concept Paper in ERCOT’s Large Load Batch Study.  The “Speed to Power” concept paper suggests several steps ERCOT can take now to deliver much needed results.

“Acknowledging that this effort is a moving target in light of many workshops to come, the paper makes an effort to propose the elements that are well-aligned across stakeholders, as well as novel ideas which have surfaced in the past few weeks, to help ERCOT consider the “minimum viable product” of rules that could enable speed to power for loads paired with dispatchability.”

Naming the Opportunity to Unlock Load Growth – “What we do not have today in ERCOT and yet seem tantalizingly close to delivering billions of dollars of investments in the Texas grid, is a way to effectuate this cadre of privately managed operational delivery risk solutions in short-range planning. A core barrier to making “speed to power” a viable (underwriting-ready) solution for “large loads”, is simply that loads and spatially proximate generation and batteries, even under a private contract that contemplates assumption of delivery risk , are not studied together in interconnection processes for net impact on grid – peak ( system peak ) and / or local peak such that ERCOT may treat them as a reduced burden on the grid in planning, and, rely on that co-optimized behavior in operations with a stiff enforcement mechanism that protects grid reliability.”

“Part of the equation has been solved for, in existing ERCOTworksimply awaiting implementation. ERCOT already has a plan to directly “talk to Loads” at a nodal, location-specific level: that plan is NPRR1188, scheduled for implementation this year. Other grid operators are struggling to make this a reality, but ERCOT already has it in motion. NPRR1255 is also an unlock: it establishes a framework for dynamic, automated bid mitigation in ERCOT’s systems. The framework was written to utilize a “just-in-time” bid-to-buy mitigation logic for battery resources, which could be used for NPRR1188-compliant loads too.0F1”

CLR as a Core Unifier Mechanism for Speed to Power in Batch Zero and Beyond – “The fundamental mechanics of CLR as proposed in PGRR134 sets up a path for voluntary early energization of the load. Market participants have proffered since the submission of PGRR134, that if a load relies on bilaterally contracted, co-located support, and those assets are unavailable to the market, the configuration should default seamlessly to CLRstatus as a price-taking load, rather than immediately forcing an automatic trip of the Load to zero. This is the unifying principle for co-located “load and gen” solutions: i.e., “if a generator trips, what happens next?”

Establishing a market for economic price signals to help loads and generators privatize deliverability to loads as a short-term planning incentive (until firm upgrades come), is predicated on getting this universal principle right: the load going to be the dispatch of last resort.

Contractual Management of CLR Offers & Long-Term Solutions – “Market participants have suggested that passing PGRR134 and related rules should allow for a simpler/nonsystems impact solution, e.g., bind a proposed CLR to a contractual duty to submit Energy Bid Curves low enough to avoid triggering shadow price cap constraints.

“This is an operations certainty issue Luminary Strategies urges ERCOT to explore in sidebar/breakouts while the batch study workshops continue. There is certainly no reason to not pass PGRR134 with amendments or additional frameworks at ERCOT’s initiative, as soon as possible: investment in grid-supportive solutions to energize loads prior to 2029 will begin the moment such language is “grey-boxed”, even if its implementation may be months away.

“The prevailing market view shared with Luminary Strategies is that CLRs should be seen as a dispatch of last resort relative to generation. CLRs do not have the same market power or withholding incentives as generation and therefore should be granted more leniency when determining bid-to-buy mitigation thresholds. The rationale for quickly mitigating generators is that they are incentivized to sell power at the highest possible price, leveraging market power. In contrast, CLRs are price takers-the concept of market power does not apply in the same way, as loads are exposed to nodal prices and act based on economic rationality rather than an intent to game the market.”

Challenges and Opportunities – “This past week in the PJM stakeholder process related to “speed to power “orders from the Federal Energy Regulatory Commission, some commenters have described that a lack of certainty in defined “pre-emergency” curtailment conditions can render speed-to-power solutions unfinanceable.5 The same could be true in ERCOT if the risk is not recognized. As ERCOT formalizes rules for provisional energization, it is critical not to inadvertently constrain what is already achievable for large loads today to provisionally energize and manage their own curtailment risk.”

“The related opportunity that must be unveiled in ERCOT is to enable a framework of “Topological Neutrality” to allow the market to solve local bottlenecks through CLRs. In the coming weeks, it will be critical to deliberate on what “flexibility in exchange for faster energization “truly looks like. For example, does ERCOT intend to articulate rules which mandating physical “co-location,” or will loads be permitted to use off-site portfolio resources to provide the necessary relief as long as the load is constrained in a “self-limiting” model?”

“It bears emphasizing that this is the literal trendline around the country for unlocking capacity. Market operators and utilities nationwide are actively embracing both on-site and off-site portfolio flexibility and innovative tariff structures to safely energize large loads faster. The Texas Advantage of getting this right is that the load customer anchors and privatizes its own transmission deliverability risk and pays full freight for firm upgrades as well – administrative intervention is limited to emergency conditions and contractual risk-taking sets the gold standard for enabling dispatchability.”