Statement: Never Again One Year Later | A Reliability Report Card

 


Austin (February 14, 2022)—Alison Silverstein, an author of last year’s “Never Again: How to Prevent Another Major Texas Electricity Failure,” has issued a report card (see below) on the first anniversary of Winter Storm Uri, grading the Public Utility Commission of Texas (PUCT), Electric Reliability Council of Texas (ERCOT), and the Texas Railroad Commission’s performance against the “Never Again” recommendations.  

The groundbreaking June 2021 report, issued by five former PUCT commissioners and Silverstein, a former senior regulatory advisor for the PUC and Federal Energy Regulatory Commission (FERC), offered specific public interest recommendations on how to fix multiple policy, operational, and planning failures across the state’s electric, water, and natural gas systems.

Silverstein says that Texas has a lot more work to do to prevent the kind of weather-driven blackouts that devastated the state in February 2021. Power and water outages affected 4.5 million meters and two-thirds of Texas residents for up to five days during bitterly cold weather. 

The report card concludes that while regulators took a handful of essential steps, Texans remain at risk because many important “Never Again” recommendations have not been implemented. Thus Texans remain at risk from another electricity, economic, and public health disaster. 

Silverstein’s “Never Again Report Card” credits the PUCT and ERCOT for requiring substantial power plant weatherization, which helped the grid operate through January and February 2022 cold snaps. However, the report card gives the Railroad Commission, which regulates Texas’ oil and gas industry, a D for minimal efforts at winterizing Texas’ natural gas system.  

Silverstein gives the PUCT, ERCOT, and the Railroad Commission Ds and Fs for failing to act on most of the other “Never Again” recommendations. 

Finally, Silverstein identifies the five most important and concerning failures to act:

  1. There has been no attention or substantive work to expand energy efficiency, which is the single most effective and low-cost way to protect Texas electric customers and its grid against the costs and risks of power system expansion and failure. 
  2. There has been a minimal effort made to study or improve ERCOT’s black-start unit rules and requirements, despite half of the black-start generation units failing during Uri. ERCOT would use black-start units to restart the grid after a total collapse and pay these units to be ready for this purpose.
  3. The PUCT has not required electric transmission and distribution utilities to examine the design and execution of their power systems and outage management plans. This review would identify potential modifications that could minimize future major outages, making them shorter, smaller, and more equitably allocated among neighborhoods and customers. Now that even more facilities have registered as “critical,” it will be even harder to manage large load-sheds equitably.
  4. ERCOT has not demonstrated a meaningful improvement in its load forecasting and seasonal and long-term resource assessments and does not acknowledge the risks and implications of extreme weather events for the reliability of Texas’ power system.
  5. And to underline the point yet again, the lack of adequate natural gas system winterization means ERCOT’s electric system reliability remains vulnerable to natural gas freeze-ups and contract and price manipulation.

The Cynthia and George Mitchell Foundation and Energy Foundation funded the "Never Again" report. 


"NEVER AGAIN" REPORT CARD GRADE KEY

A = very good

B = reasonable measures taken

C = moving toward action

D = minimal 

F = totally ignored problem to date

I = incomplete—started but little progress to date

n/a = not applicable to this entity

--- = limited role or following other entity’s lead

"NEVER AGAIN" RECOMMENDATION


   PUCT

  ERCOT

Railroad Commission

      Comments

1. Power plants didn’t operate in extreme cold


 

 

 

 

1-1  Weatherize natural gas production and pipelines

    n/a

    n/a

    D

Minimal Railroad requirements, to date only identifying “critical infrastructure” without requiring specific weatherization measures

1-2  Electric power plant winterization

    B

    A

    n/a

PUCT implemented winterization to 2011 event recommendations, working on firm fuel measures

2. Electric demand skyrocketed in cold


 

 

 

 

2-1  Update energy efficiency building codes

    n/a

    n/a

    n/a

Requires legislative action

2-2  Raise utility efficiency program goals and funding

    F

    n/a

    n/a

PUCT can act without legislative approval

2-3  Increase low-income energy-efficiency retrofits

    F

    n/a

    n/a

Legislative action would push this

2-4  Increase emergency demand response

    D

    D

    F

Increased for winter by moving seasonal funds, but no substantive DR changes for residential customers.  No gas DR.

3. Distribution utilities didn’t rotate outages


 

 

 

 

3-1  Utilities should sectionalize distribution circuits

    F

    n/a

    n/a

No study or requirements initiated

3-2  Large customers should reduce load remotely

    F

    n/a

    n/a

No study or requirements initiated

3-3  Critical facilities should have backup power

    F

    n/a

    F

Requires legislative and municipal action or TDU initiative. No PUCT consideration

4. Poor demand & supply forecasting and planning


 

 

 

 

4-1  ERCOT to improve demand forecasting

    D

    D

    n/a

Little public evidence of improvement. Winter 2022 storm forecasting was significantly off

4-2  ERCOT to use better scenario analysis

    F

    F

    n/a

Last two SARA reports use old methodology. Nov 2021 winter extreme case scenario demand far below recent weather event peak projections

4-3  Recognize & adjust for extreme weather threats

    F

    F

    F

Last two SARA reports ignore climate extremes

5. Power market operation was ineffective


 

 

 

 

5-1  Evaluate ERCOT summer v. winter protocols

    I

    D

    n/a

Minimal effort to date

5-2  Reassess and toughen black-start

    F

    C

    n/a

No action to date; ERCOT task force working

5-3  No “generation capacity reserve”

    D

    D

    n/a

PUC studying generation reserves and capacity payment proposals. ERCOT spending for RUC and NSRS like reserve payments

6. Inadequate or inappropriate governance


 

 

 

 

6-1  Strengthen Public Utility Commission

    C

    n/a

    n/a

New commission members but little additional staff or funding authorized

6-2  Improve ERCOT Board of Directors

    --

    I

    n/a

Legislative requirement

6-3  Establish active compliance oversight

    A

    A

    D

ERCOT inspections and PUCT fines are a big step forward

6-4  Study ERCOT interconnection to neighboring grids

    D

    --

    n/a

No study initiated yet and no funding authorized. PUCT expediting consideration of Southern Cross project.

7. Causes of the Uri blackout


 

 

 

 

7-1  Investigate Uri failure causes and release all findings to public

    B

    B

    F

University of Texas at Austin report for PUC, FERC-NERC report, ERCOT Reliability Roadmap

7-2  Routinely collect electric and gas information and share publicly

    C

    C

    F

PUCT conducting minimal analysis of potential reliability and cost impacts of proposed policy changes.  ERCOT data reporting is poorly organized and hard to use.  RRC data is limited, late, and publicly misrepresented.


 

For more information, contact Brett Holmes at bholmes@cgmf.org or (713) 244-4178.

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