Navigating 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 — and the clock is ticking. 

In April, 427 resources filed for relief. ERCOT’s review found that not a single submittal fully met all requirements. With the September 15, 2025 deadline fast approaching, developers, asset owners, and consultants have a narrow window to address critical gaps. 

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. 

These requirements significantly increase the technical and procedural workload to accurately file for extension or exemption requests. 

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 

Any of these gaps can trigger outright rejections that could require resources to comply with the NOGRR245 requirements even if they cannot. 

How EPE Can Help You Close the Gaps

At Electric Power Engineers, we’ve guided thousands of projects through ERCOT’s evolving rules and technical standards. Our team brings: 

• Proprietary Model Benchmarking Tools to quickly verify PSSE and PSCAD compliance 
• Practical Parameter Tuning that balances maximized ride-through performance with real-world operational constraints 
• OEM Engagement Support to streamline the affidavit process and avoid last-minute document scrambles 

Because we’ve been involved in ERCOT market changes from the start, we can identify and resolve compliance gaps before they become costly roadblocks. 

Act Now to Protect Your Project Schedule

If you have an extension or exemption pending — or you’re not confident your submittal will pass ERCOT’s tightened review — now is the time to take action. 

The September 15 deadline leaves no margin for error. Let’s map your compliance path now so your project stays on track. 

Contact my team below to schedule a rapid compliance assessment.