Texas grid reform report card is in, and it isn’t good

Following the historic and crippling grid failure caused by Winter Storm Uri in February 2021, the state of Texas — Gov. Greg Abbott and a bipartisan collection of elected leaders — pledged to ensure such a catastrophic disaster would never happen again.

The state Legislature, already in session, launched a series of hearings to find causes and culprits. Several organizations and energy experts provided state leaders suggestions and guidance; EDF was one of them. Our detailed report to the Legislature, issued in February 2021, recommended eight specific areas on which the state’s examination should focus.

Following the Legislature’s modest action, Gov. Abbott famously exclaimed, “Everything that needed to be done was done to fix the power grid in Texas.”

A look back at what’s actually been done so far to strengthen the grid, however, tells a very different story. Comparing the state’s action against EDF’s suggestions reveals a remarkably lackluster response to the biggest failure of state infrastructure and oversight in recent memory.

As we prepare to recognize the first anniversary of the grid failure, EDF graded the state’s response against our eight core recommendations.

  1. Forensic analysis of Winter Storm Uri and prior winter energy failures
    Grade: B
    Comments: The University of Texas performed a good but limited study for the state Public Utility Commission. The Federal Energy Regulatory Commission and the North American Electric Reliability Corporation performed a more detailed study that identified many causes, failures and recommendations. EDF’s B grade reflects the state’s willingness to get non-agency assessments, but also its failure to act adequately on both reports’ conclusion that the natural gas supply played an outsized role in the disaster. Both studies were released after the legislative session, and reaction to their findings and recommendations has been mixed.
  2. Mandatory power plant weatherization and natural gas production and delivery requirements
    Grade: Incomplete
    Comment: The PUCT adopted basic winterization requirements for power plants based on recommendations developed after the 2011 Texas freeze and electric and gas system failures. Those requirements may be modified this year to reflect anticipated winter and summer extreme weather threats. However, the Texas Railroad Commission has not yet adopted any winterization requirements for any portions of the natural gas production, processing, storage or delivery system, even though the gas supply system failure was a primary cause of the 2021 grid failure and associated deaths and property damages.
  3. Prepare all critical utility systems to meet more extreme weather events. Study potential impact of extreme weather on power system equipment
    Grade: Incomplete
    Comment: The Legislature directed the Texas State Climatologist and the Electric Reliability Council of Texas to prepare a study of future extreme weather conditions, but that study is not yet complete. However, there is enough technical information available about the impacts of climate change that utilities could already be studying how to prepare their assets to better deal with hurricanes, ice storms, heat waves and other threats. Other than water treatment systems, there has been little attention paid to preparing other critical utilities (wastewater, communications, health care) to operate through future extreme weather events.
  4. Pursue aggressive energy efficiency for housing and offices, including funding for energy improvements for low-income and multi-family housing, raising efficiency goals and adopting ambitious energy efficient building codes
    Grade: F-
    Comment: The PUCT has not undertaken any action to expand energy efficiency to improve grid reliability and deliver economic and health benefits for customers and the state economy.
  5. Study the impact of 2021 Uri outages on utility customers and implement policies to reduce inequities. For example, examining the effectiveness and fairness of large-scale outages, modifying systems to enable fairer outage allocation and requiring large commercial & industrial customers to use remote load-shed to protect residential customers
    Grade: F
    Comment: The state has not examined the equity impacts of Uri or other outages. The state has not studied nor directed any infrastructure changes that would improve outage equity/allocation and has not established any remote load-shed requirements for large customers.
  6. Study interconnection to other regions
    Grade: D
    Comment: No study, no discussion, no funding. Although the Legislature directed the PUCT to conduct such a study, it did not authorize any funding for this purpose, so the PUCT has not yet begun work on the study. However, the PUCT recently expedited consideration of the long-pending Southern Cross transmission project application, which, if approved, would build transmission from ERCOT into Louisiana and Mississippi.
  7. Strengthen ERCOT transmission grid and expand power deliverability
    Grade: C-
    Comment: PUCT approved transmission expansion within the Rio Grande Valley and asked ERCOT to expedite interconnection for new dispatchable resources. Other than transmission winterization, there has been no action to improve existing transmission infrastructure and throughput.
  8. Examine whether any of 2021 Uri failures were created or worsened by Texas regulations and policies.
    Grade: Incomplete
    Comment: The PUCT modified the ERCOT energy price cap and ORDC price curve and changed pricing during grid emergencies. The agency is looking at several other potential market changes to try to incentivize additional power supply and retain existing resources. However, the PUCT and ERCOT have not performed or publicly released any detailed analysis of reliability or cost implications of the market and operational changes being considered.

Beyond these specific recommendations, our report also included some guidelines or criteria we suggested should guide the state’s reform efforts. Some of these criteria are subjective and hard to grade:

  • Prioritize people, not just the grid, now and for the future.
  • Examine and prepare Texas communities and infrastructure systems for the full scope of extreme weather threats related to a changing climate.
  • Recognize the connection/dependence of our electricity, gas and water systems
  • Focus equally on better management of Texas’ energy supply and demand
  • Examine and improve the market, grid management and emergency response
  • Examine ERCOT and PUCT authority, governance and representation.

It’s clear that the state’s limited policy priorities and remedies so far bear little resemblance to EDF’s recommendations and guidelines. The state did not examine the full scope of impacts of extreme weather events. It has not addressed the interdependence between the electricity, gas and water systems. So far, it has completely ignored the demand side opportunities associated with our complex electric system.

Given the state’s limited progress on winter energy challenges, EDF is concerned about policymakers’ refusal to recognize the ways that renewable energy can strengthen the grid, and we are concerned about proposals that would make cheap, clean renewable power more expensive. EDF will continue advocating to increase efficiency investment in Texas homes — an enormously cost-effective and life-saving strategy that will provide benefits for years to come.

Anniversaries call for reflection and recommitment to important goals. EDF’s sincere hope is that as we near the first anniversary of the Winter Storm Uri disaster, this troubling report card spurs fresh reforms that more directly and aggressively assess these and other options to fortify our grid and protect Texans. We would be thrilled to recognize improvements in February 2023.

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