The Steering Committee of Cities Served by Oncor filed comments January 4 in response to the proposed rules.


As part of their ongoing response to last February’s winter storm, Texas regulators have proposed updated requirements for Emergency Operations Plans (“EOP”) required from ERCOT market participants.

Attorney Thomas Brocato

Unveiled in a PUC staff filing on December 1, the proposed new requirements potentially affect a wide array of market participants, including generators, electric co-operatives, municipally owned utilities, transmission and distribution providers, retail electric providers, and even ERCOT itself.

Under the PUC’s proposed new requirements, such entities must submit a list of emergency contacts with the agency. They also must submit an affidavit attesting they have conducted appropriate drills, they have business continuity plans, they have plans for communicating with the public during an emergency, and they have plans for handling complaints.

In addition, EOPs must show how such entities identify weather-related hazards, and include operational plans to mitigate hazards from weather emergencies. Relevant entities with control over load shedding—that is, the cutting of electricity power to end users as a means to maintain overall electric grid reliability—must include descriptions of their load-shedding procedures and stipulate priorities for power restoration.

The Steering Committee of Cities Served by Oncor (“OCSC”), a municipal coalition, filed comments January 4 in response to the proposed rules. In those comments, OCSC said that the PUC should make transparency a priority with the new EOPs.

“Accountability is especially important with regard to communications plans,” wrote attorney Thomas Brocato on behalf of OCSC. “The end product for which EOPs are used should be readily available to the utility and customer communities wherever possible. At a minimum, the Commission should require an entity making a claim of confidentiality to show specifically why each component of the filing is confidential.”

OCSC also noted that the PUC should leverage information from EOPs to the greatest extent possible. “The hundreds of EOPs filed by industry members that will be available to the Commission will contain a wealth of information informing future public policymaking if there are resources committed sufficient to take advantage of that information,” Mr. Brocato wrote.

The proposed EOP rules are a requirement of Senate Bill 3, adopted during the most recent legislative session. The PUC will finalize the new requirements at a later date after considering stakeholder comments. The proposed requirements be found on the PUC Interchange under Project No. 51841.

— R.A. Dyer