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Comments Sought in 5-Year Review of System-wide Offer Program
On August 20, 2026, Staff of the Public Utilities Commission of Texas (PUCT) issued a memo seeking comments from stakeholders regarding the review of system-wide offer cap program under 16 TAC 25.509(D).
Every five years, the Commission will review each of the system-wide offer cap programs to determine whether updates may be warranted. Calendar year 2026 marks the first review period for these programs.
Comments are due by September 17, 2026.
To assist with the Commission’s review, Commission Staff requests responses to the following questions for comment:
Scarcity Pricing Mechanism (SPM)
The current Low System-Wide Offer Cap (LCAP) is $2,000 per MWh for energy offers and $2,000 per MW per hour for ancillary service (AS) offers. The current High System-Wide Offer Cap (HCAP) is $5,000 per MWh for energy offers and $5,000 per MW per hour for ancillary service offers. Do either of these values need to be updated? Why?
With the implementation of RTC+B, there is a difference between the day ahead (DAM) and real-time (RTM) system offer caps for both energy and AS. The DAM offer cap is $5,000 per MWh per hour, and the RTM offer cap is $2,000/MWh. Should this difference continue? Why?
Should any of the scarcity pricing mechanism features listed below be modified? Why? i. Peaker net margin calculation ii. LCAP trigger threshold iii. Reimbursement for operating losses when the LCAP is in effect.
Emergency Pricing Program (EPP)
Since its adoption in December 2023, ERCOT has never activated the EPP. Should any of the EPP features listed below be modified? Why? i. The activation trigger for the EPP ii. The Emergency Offer Cap iii. The duration of the EPP iv. The market notice specifications v. The reimbursement for costs that exceed the ECAP vi. The reporting requirements after the EPP has been activated
How should the Ancillary Service Demand Curves (ASDC) be modified to better reflect scarcity and improve economic efficiency?
What credit risk concerns should the Commission consider if either the SPM or the EPP were to be adjusted, and how should existing credit obligations be recalibrated in response?
Are there any other topics the Commission should consider as part of this evaluation?
