ERCOT’s NOGRR245 Extension & Exemption Requests: What Developers Need to Do Before September 15

ERCOT’s third NOGRR245 workshop confirmed what many in the market suspected: exemption and extension requests are proving to be more challenging than expected.

In April, 427 resources filed for relief. ERCOT’s review found that not a single submittal fully met all requirements.

Key Takeaways and Why It Matters

ERCOT’s latest workshop highlighted several key items:

• Dual Modeling Requirements
  Both PSSE and PSCAD models must reflect maximized ride-through capability, not just nominal performance.
• Model-Quality Alignment
  Model-quality tests must align with the PGRR109 Model Review Process — raising the bar for accuracy and validation.
• Mandatory OEM Documentation
  An OEM-signed letter confirming technical limitations is required. In cases where this is not obtainable, ERCOT may accept a notarized attestation.

Where Projects Are Stalling

The most common deficiencies highlighted in ERCOT’s latest workshop include:

• Detailed description of technical limitations preventing Resource from meeting ride-through requirements
• Post-modification Resource capability along with PSSE & PSCAD plant models reflecting any expected remaining limitation(s)
• Under-Optimized Ride-Through Parameters that fail to demonstrate realistic, maximized performance
• OEM Coordination Delays in securing the required IFRTCR/IVRTCR documentation.

How EPE Can Help

These requirements significantly increase the technical and procedural workload to accurately file for extension or exemption requests. Developers, asset owners, and consultants have a narrow window to address critical gaps by the September 15, 2025 deadline.

EPE engineers want to help you. Our experts can review your specific situation and work with you to find a path forward.  If you have an extension or exemption pending — or you’re not confident your submittal will pass ERCOT’s tightened review — reach out. Fill out the form below and we will be in touch shortly.

 Contact my team using the form below to schedule a consultation.