The Texas Competitive Power Advocates (TCPA) and Exelon Corp. have urged the Public Utility Commission of Texas to take a more deliberate pace to the PUCT's study of subsynchronous oscillation (SSO), noting the "highly technical" nature of the issue, and alleging that various SSO studies are not "sufficiently comprehensive."

We take here no stance on the merits of the generators' concerns related to the SSO proceeding, but are struck by how similar this is to certain concerns raised in the resource adequacy proceeding.

There, certain stakeholders raised concerns that Texas was rushing into a similarly highly technical morass, and that the Commission was not evaluating the resource adequacy problem on a comprehensive basis, because projections were based on inaccurate and uncoordinated load forecasts and studies.

Of course, in that proceeding, generators were the ones pushing for a quick resolution, dismissing calls for a more deliberate approach, and we must note the distinction between the two proceedings. In the capacity market, generators stood to be the beneficiaries of a large windfall, with load having to pay the costs of the new policy. Now, however, when the shoe is on the other foot, with some of the SSO proposals calling for generators to undertake costly compliance measures, they do not espouse the same urgency in resolving the case, and want to slow things down.

Here are some comments from the generators urging more deliberation in the SSO proceeding (made in Project 42631). Simply swap out SSO for capacity market, and this could pass for a filing from TIEC.

"As TCPA stated in its original comments, and Exelon agrees, SSO is a highly technical phenomenon that can result in catastrophic [results]."

"The Commenters continue to believe that implementing a rule without a more complete understanding of the potential impacts of SSO on the ERCOT system will not adequately address the serious reliability and economic consequences ..."

"The Commenters' companies have become increasingly concerned that the ERCOT SSO studies performed to date have not been coordinated with all affected parties, and are not sufficiently comprehensive to fully identify SSO risks for every generation unit in the system."