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Texas RE is authorized by the Public Utility Commission of Texas (PUCT) to serve as the PUCT's Reliability Monitor for the ERCOT region.

As the PUCT’s Reliability Monitor for the ERCOT region, Texas RE:

  • Monitors, audits, investigates, and assesses compliance with the reliability-related provisions of the Public Utility Regulatory Act, PUCT Substantive Rules, ERCOT Protocols, and ERCOT Operating Guides by ERCOT and ERCOT Market Participants.
  • Analyzes ERCOT reliability-related events and prepares reports.
  • Evaluates proposed changes to ERCOT Protocols, Operating Guides, and Other Binding Documents to identify potential reliability impacts.
  • Provides subject matter advice, expertise, and support for PUCT oversight and enforcement activities.

Texas RE uses separate personnel to perform Protocol Compliance activities than the personnel it uses to perform NERC Reliability Standards compliance and enforcement activities. Protocol Compliance activities are performed by Texas RE's Protocol Compliance Department.

For questions regarding Protocol Compliance, please contact Texas RE Protocol. 

Audits

Audits may cover a variety of areas addressed by reliability-related requirements in the ERCOT Protocols and Operating Guides. Audit Scope periods are established at the time the Market Entity being audited is notified of the audit. Audits may be “table top” audits conducted at Texas RE offices or “on-site” audits at the entity’s location, or may use a combination of the two techniques.

Before the audit start date, Texas RE will send an email notifying the entity of the audit date. The entity will receive details about the audit including the audit questionnaire(s) prior to the audit start date. Upon completion of the audit, Texas RE issues a Protocol Audit Report and reports possible violations to PUCT for appropriate enforcement action.

Spot Checks

Protocol Compliance also conducts limited scope audits, which are referred to as Spot Checks. The notification and response times are usually shorter than those for a broader scope audit, and are determined based on the number of requirements included in the Spot Check. Spot Checks do not ordinarily include site visits.

The PUCT is responsible for enforcement actions related to violations of ERCOT Protocols and Operating Guides. Texas RE Protocol Compliance Department personnel provide technical support for PUCT enforcement actions, which may include testimony services.

In cases where the Protocol possible violation is also the subject of possible NERC compliance activities, Texas RE will not disclose any non-public information about the NERC compliance activities to PUCT due to confidentiality requirements. However, the entity may authorize Texas RE to share information about NERC compliance activities with PUCT, or may choose to share information about the NERC compliance activities with PUCT staff so that the PUCT may consider it in the Protocol enforcement action.

The Texas RE Protocol Compliance Department conducts investigations of significant events on the ERCOT system, such as Energy Emergency Alerts (EEA). The Protocol Compliance Department may issue data requests to entities to obtain information regarding the Market Participant's performance and compliance with reliability-related ERCOT requirements. Compliance analysis may lead to formal investigations and identification of possible violations.

Texas RE submits the results of the investigation to the PUCT for further review and possible enforcement action.

Documents

Protocol and Operating Guide Compliance Report - Feb. 2, 2011 - Energy Emergency Alert Level 3 Event
Protocol Compliance Report - October 8, 2014 - Load Shed Event

A Protocol Mitigation Plan should be prepared by a Market Entity who has self-reported a possible violation of an ERCOT reliability-related requirement or in response to a request from Texas RE. The Mitigation Plan provides an explanation of the following:

  • Description of the possible violation;
  • Cause of the possible non-compliance;
  • Detailed plan to correct the possible non-compliance and prevent recurrence;
  • Milestone schedule, if needed;
  • Expected completion date; and
  • Name of contact person.

Protocol Mitigation Plans may be submitted by completing the Protocol Mitigation Plan Form and emailing it to Texas RE Protocol.

Documents

Protocol Compliance Mitigation Plan

The Texas RE Protocol Compliance Department monitors compliance of ERCOT Market Participants with the ERCOT Protocols, including performance metrics described in Section 8 of the Protocols. Review of ERCOT reports and operational data may lead the Protocol Compliance Department to issue data requests to entities to obtain further information regarding the Market Participant’s performance and compliance with reliability-related ERCOT requirements.

Following review, Texas RE submits the results of the investigation to the PUCT for further review and possible enforcement action.

If an ERCOT Market Participant identifies a possible violation of a reliability-related ERCOT Protocol or Operating Guide, that entity should self-report the possible violation to Texas RE.

Texas RE’s Protocol Compliance Department reviews Self-Reports and may request additional information and a Mitigation Plan from the Market Participant. Following review, Texas RE submits its evaluation of the Self-Report to the PUCT for further review and possible enforcement action.

Protocol Self-Reports may be submitted by completing the Protocol Self-Report Form and emailing it to Texas RE Protocol.

Documents

Protocol Compliance Self Report
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