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Under Settlement Agreement with PUCT Staff, Garland Power and Light System Agrees to Administrative Penalty of $375,000
For failure to comply with ERCOT Nodal Protocols related to the provision of ancillary services and Non-Spin deployment requirements
On March 27, 2026, the Staff of the Public Utility Commission of Texas (PUCT) and Garland Power and Light System (Garland) filed a settlement agreement and report regarding Garland’s violations of PURA § 39.151(j); 16 Texas Administrative Code (TAC) §25.503 (f)(2); and Electric Reliability Council of Texas, Inc. (ERCOT) Nodal Protocols § 8.1.1.3(3) and 8.1.1.4.3(3)(a) and (b).
“For the purpose of supporting the Commission’s Order in this proceeding, Commission Staff, on behalf of itself and Garland, moves to admit the settlement package filed on March 27, 2026, including all attachments, into the record of this proceeding as evidence.”
“Commission Staff recommends, and Garland agrees to, an administrative penalty of $375,000, an amount equal to excess revenues realized due to, and in resolution of, the violations.”
Alleged violations include:
Violation of 16 TAC * 25.503(f)(2) 13.
“Under 16 TAC § 25.503(f)(2), a market participant must comply with ERCOT procedures and any official interpretation of the ERCOT Nodal Protocols issued by ERCOT or the Commission.
Staff alleges that Garland violated 16 TAC § 25.503(f)(2) on 15 days in the period between November 8, 2021, and February 24, 2022, by failing to comply with ERCOT Nodal Protocols related to the provision of ancillary services (AS).”
Violation of ERCOT Nodal Protocols #8.1.1.3(3)
Under ERCOT Nodal Protocols § 8.1.1.3(3), a QSE must, within ten minutes of receiving the insufficient capacity notification from ERCOT:
- If due to a telemetry issue, correct the telemetered Ancillary Services Resource Responsibility to provide sufficient capacity; or
- Provide both appropriate justification for not satisfying its Ancillary Service Obligation and a plan to correct the shortfall that is acceptable with the ERCOT operator. ERCOT shall report non-compliance of Ancillary Service capacity requirements to the Reliability Monitor for review.
Staff alleges that Garland violated ERCOT Nodal Protocols § 8.1.1.3(3) on 15 days in the period between November 8, 2021, and February 24, 2022, by failing to comply with ERCOT Nodal Protocols related to the provision of AS.
Garland asserts that prior to the period in question, the ERCOT Board of Directors had approved a change in Nodal Protocols § 8.1.1.3(3) on February 12, 2021, extending the time of compliance for the provision of AS from ten minutes to twenty-five minutes. The change went into effect in April 2024. Garland asserts that many of the alleged violations identified by Commission Staff would not have been violations under the Board-approved version of the Nodal Protocols.
Violation of ERCOT Nodal Protocols # 8.1.1.4.3(3)
Under ERCOT Nodal Protocols § 8.1.1.4.3(3), control performance during periods in which ERCOT has deployed Non-Spin shall be based on the requirements below and failure to meet any one of these requirements for the greater of one or five percent of Non-Spin deployments during a month shall be reported to the Reliability Monitor as noncompliance:
- Within 20 minutes following a deployment instruction, the QSE must update the telemetered Ancillary Service Schedule for Non-Spin for Generation Resources and Controllable Load Resources to reflect the deployment amount.
- Off-Line Generation Resources, within 25 minutes following a deployment instruction, must be On-Line with an Energy Offer Curve and the telemetered net generation must be greater than or equal to the Resource’ s telemetered LSL multiplied by Pl where Pl is defined in the “ERCOT and QSE Operations Business Practices During the Operating Hour.” The Resource Status that must be telemetered indicating that the Resource has come On-Line with an Energy Offer Curve is ON as described in paragraph (5)(b)(i) of Section 3.9.1, Current Operating Plan (COP) Criteria.
Staff alleges that Garland violated ERCOT Nodal Protocols § 8.1.1.4.3(3)(b) on 10 times in the period between July 2022 and November 2022 by failing to provide the minimum net generation within 25 minutes as required by ERCOT Nodal Protocols related to the monthly performance metrics.
Garland asserts that for these alleged incidents, ERCOT failed to consistently follow Resource Desk Operating Procedure Manual Sections 3.1, which states that if a “discrepancy is identified between a COP and telemetered Resource Status” then the Resource Desk Operator would “call the QSE representing Resource to determine the correct resource status and have them make the necessary correction.”4 Garland alleges ERCOT did not make that phone call in many of the incidents, thereby failing to follow communication standards from the grid operator that generation resource owners rely upon to prevent such incidents.
