The Public Utility Commission of Texas (PUCT) is going through the complex process of establishing “firming” requirements, which will dictate how generators must provide dependable electricity during high-risk periods (such as winter storms or severe heat waves).
It’s vital that commissioners strike the right balance between cost and reliability — and TEBA submitted comments to the PUCT with options for doing just that.
We support parts of the PUCT’s draft firming proposal, especially its intent of strengthening the ERCOT grid. By making a few adjustments, the Commission can increase reliability without unaffordably driving up energy costs or slowing the new resources that Texas needs.
Key changes include the following:
1. Firming requirements should better recognize the role that batteries play on the grid. Indeed, batteries are specifically exempted from firming requirements by law, yet the PUCT’s draft proposal subjects batteries to these requirements in a way that limits the reliability boost they can provide. Batteries should be able to use their full capacity to firm up other resources.
2. By the same token, existing generators are supposed to be exempt from these firming requirements, yet the proposal would apply the requirements to them or take away the exemption when generators expand. This is certain to make energy much more expensive, and it could actually decrease reliability by discouraging companies from increasing generation.
3. The draft proposal sets out a methodology for predicting “high-risk hours” when firming would be required — and that methodology appears to result in far more high-risk hours than ERCOT’s real-world experience says Texas should expect. Again, this unrealistic red tape will substantially increase costs without increasing reliability.
4. The draft requirements would negate some of the very attributes that make some energy sources valuable. For instance, solar power plants could have to “firm” at night — a time when no one expects them to be producing electricity. Solar is valuable because it’s cheap and predictable; this would needlessly make it much more expensive.
There’s more: read our full comments here: https://interchange.puc.texas.gov/search/documents/?controlNumber=58198&itemNumber=61