Tackling Transmission Congestion: Are You Prepared for Extended Action Plans Within ERCOT?

Tackling transmission congestion doesn’t always require new infrastructure. In some cases, existing facilities can be strategically reconfigured to ease bottlenecks and unlock greater revenue potential for suppliers.  

On July 25, 2024, the Public Utility Commission of Texas (PUCT) approved NOGRR-258 and NPRR-1198, formally establishing the Extended Action Plan (EAP) framework within ERCOT’s Constraint Management Plan (CMP) process. These revisions introduce a flexible and scalable approach to managing transmission congestion through pre-contingency topology reconfiguration, even when congestion is resolvable through Security-Constrained Economic Dispatch (SCED). 

Key Criteria for Extended Action Plans: 

• EAPs proposed for economic reasons are eligible only if the associated congestion exceeded $2 million in a single month or $5 million over any three-month period within the past 36 months. 
• Cost-Effectiveness Requirement: Each EAP must demonstrate at least $1 million in expected production or congestion cost savings compared to conventional generation re-dispatch solutions. 
• Switching Constraints: EAPs must be limited to reconfigurations involving three or fewer substations. 
• Restrictions: No load shedding or generation re-dispatch is permitted within the scope of the EAP itself. 
• All EAPs must be restored to normal grid configuration as soon as a transmission upgrade is completed or temporary congestion ends. For chronic congestion, EAPs must still have a proposed end date. They must also undergo annual reviews to ensure ongoing effectiveness and system value. 

Implementation of EAPs: 

• Each EAP must be pre-approved by ERCOT, the impacted Transmission Operators (TOs), and directly affected Resource Entities, excluding those affected solely by price changes. 
• Each EAP must pass technical screening to ensure it does not create new or worsen existing thermal constraints, result in radial load, or interfere with scheduled outages. 
• Be modeled, submitted, and managed through the Network Operations Model Change Request (NOMCR) and Outage Scheduling processes. 
• Be subject to temporary suspension by ERCOT or TOs for reliability reasons or outage conflicts. 

Project Mini-Case Study:  

In a recent study, EPE worked with a client operating a coal-fired power plant that has consistently delivered dispatchable power to the ERCOT market since 2012. The growing transmission constraints began to limit the plant’s ability to supply power effectively.  

In order to address these issues, the EPE team conducted a detailed analysis and root cause assessment, guided by the established EAP framework. We synthesized numerous data inputs, including congestion rents, generation shift factors, generic transmission constraints and the potential for specific switching activities to improve outcomes for the facility.  

This effort led to the identification and successful proposal of targeted network reconfiguration activities intended to alleviate the congestion impacting the plant. EPE provided the client actionable, valuable findings that allowed them to make timely, data-driven decisions to improve their standing in the market.  

This project demonstrates how EAPs can provide practical, system-level solutions to improve grid flexibility and unlock stranded generation capacity.