Mitigation Planning – ERCOT Protocols and Operating Guides

A mitigation plan is an organization’s proposal to reduce or alleviate the potentially harmful impact of alleged or confirmed violation(s) of the Electric Reliability Council of Texas (ERCOT) Protocols or Operating Guides.

A violation of an ERCOT market rule(s) requires that a mitigation plan be submitted to Texas Reliability Entity, Inc. (Texas RE) for evaluation and potential acceptance by Texas RE and the Public Utility Commission of Texas (PUCT).

Whether the violation is alleged (meaning that it is being evaluated by Texas RE) or confirmed, Texas RE strongly encourages that the entity develop and submit a mitigation plan as early as possible, in order to assure the reliability of the power grid.

Mitigation plan forms are in the forms section below. Please submit all forms to protocols@texasre.org .

Mitigation Plan Information

As seen in the mitigation plan forms provided, the mitigation plan includes the following:

• The entity’s point of contact, who is (1) responsible for filing the mitigation plan, (2) technically knowledgeable, and (3) authorized and competent to respond to Texas RE questions regarding the status.
• The violation(s) (alleged or confirmed) the mitigation plan will correct.
• The cause of the violation(s).
• The action plan to correct the violation(s).
• The action plan to prevent recurrence.
• The anticipated impact of the mitigation plan on bulk-power system (BPS) reliability and an action plan to mitigate any increased risk to BPS reliability while the mitigation plan is being implemented.
• A timetable for completion including the date by which time the mitigation plan will be fully implemented.
• Implementation milestones
  • no more than three months apart
  • with expected completion dates no more than three months from the mitigation plan’s date of submission.

A mitigation plan should include any additional information that the entity deems necessary or appropriate.

A mitigation plan may be submitted at any time. However, the entity must submit a mitigation plan within thirty days after being served a notice of alleged violation and penalty or sanction.

The entity must provide updates on the progress of the mitigation plan to Texas RE on a quarterly basis, at a minimum. Texas RE tracks the mitigation plan to its completion and may conduct onsite visits and/or review the plan’s status during audits.

Upon completion of the mitigation plan, the entity must provide a signed letter that all required actions have been completed. The entity must include sufficient data or information to verify completion. Texas RE may request data or information and conduct follow-up assessments, spot checks, or audits as verification.