A Free-Market Energy Blog

ERCOT Readies ‘Retired’ Gas Generation for the 2023/24 Winter Peak

By Ed Ireland -- October 4, 2023

“Much of the generation named by ERCOT as qualified under their latest RFP is generation units that were recently retired, many because they could not compete with the artificially low prices that heavily subsidized wind and solar can offer, so they are still operational.”

The Electric Reliability Council of Texas (ERCOT), the planning agency for 90% of the state’s grid, has a wind/solar tiger by the tail. As the agency does not exchange power with its out-of-state neighbors to avoid federal (FERC) jurisdiction, it is looking at home for able, firm generation that wind and solar unfairly (via government intervention) put out of operation.


ERCOT is (in)famous because its grid almost collapsed during Winter Storm Uri in February 2021. The Texas electricity grid had lost so many generators due to the storm that it was only 4 minutes and 37 seconds from collapsing, which would have required a restart from a “black start.” That would have left the Lone Star State without electricity for eight days or longer. ERCOT instituted emergency measures, including rolling blackouts, that saved the grid and its integrity.

As it was, hundreds of cold-related deaths and ruined lives and property otherwise represented the worst electricity (and energy) debacle in American history. Tens of billions of dollars of disputed power payments are working their way through the courts.

The state of Texas and ERCOT never want to be in that situation again.

The summer of 2023 pushed the ERCOT grid close to rolling blackouts on many evenings around 8 PM in July and August as the sun set and the wind stopped blowing, resulting in no solar power and little or no wind power. These situations occurred on many evenings during July, August, and September—with September 6, 2023, pushing the grid to a Level 2 emergency, which gave ERCOT additional resources to stabilize the grid.

Winter Preparations

To avoid more emergencies, ERCOT issued a Request for Proposal (RFP) to secure backup generation for the 2023-2024 winter. The RFP for “Firm Fuel Supply Service” would be for on-demand power generation from November 15, 2023, to March 15, 2024 with a due date of September 1.

ERCOT received proposals from five Qualified Scheduling Entities. QSEs are pre-qualified power wholesalers who buy and sell electricity on the wholesale market and act as intermediaries between individual independent generators.

The five QSEs that responded offered 32 different generating stations that could provide guaranteed backup power whenever ERCOT calls for it:

  • All 32 Generation Resources were entirely natural gas-fired power generation facilities and were awarded $9,000/MW (the cap established by the Public Utility Commission of Texas).
  • 31 of the 32 Generation Resources will be backed up by fuel if natural gas is not available.
  • One “Generation Resource” offered natural gas storage to guarantee their ability to maintain their natural gas supply
  • A total of 3,319 MW of FFSR was procured with a projected total cost of procurement of $29.9 million.

By comparison, the first Firm Fuel Supply Service ERCOT obtained (November 15, 2022, through March 15, 2023) was 43% more expensive for 13% less power capacity.

Since the off-peak daily clearing prices for natural gas generation averages $20 per MW, $9,000 per MW is high. However, these generators provide standby generation and guarantee it will be available whenever ERCOT calls for it.


In addition to “Firm Fuel Supply Service” above, ERCOT issued another call on October 2, 2023, for additional winter generation, titled “Request for Proposals for Capacity,” even though ERCOT considers their grid an energy-only market. Proposals are due this November 6.

ERCOT specifically highlighted that grid reliability problems had been caused by (1) load growth, (2) recent and proposed retirements of “dispatchable Generation Resources” (which means natural gas-fired generators), and (3) the possibility that recent winter weather events could be repeated:

ERCOT has determined that if the ERCOT Region experienced a winter storm during the 2023-24 winter Peak Load Season comparable to Winter Storm Elliott in December 2022, the risk of entering into an Energy Emergency Alert (EEA) during the highest-risk hour (Hour Ending 8 a.m.) would be approximately 19.9%. 

This would exceed the 10% probability level that constitutes an “elevated” risk under the standard ERCOT has employed for purposes of its studies conducted in support of NERC’s winter resource adequacy assessments.  While ERCOT is not projecting that EEA conditions are likely to occur, ERCOT nevertheless finds this elevated risk of EEA unacceptable.  ERCOT has determined that approximately 3,000 MW of additional capacity would be needed to reduce the probability of EEA below this 10% elevated-risk threshold. 

Based on the risk identified in ERCOT’s analysis, ERCOT intends to issue a request for proposals (RFP) to procure up to 3,000 MW of generation or Demand response capacity for the winter 2023-24 Peak Load Season (December 2023 through February 2024).

ERCOT identified by name the mothballed generation that qualify to respond to its RFP:

  • Ten named “Mothballed Dispatchable Generation Resources (as of December 1, 2023)”
  • Four named “Seasonally Mothballed Dispatchable Generation Resources (as of December 1, 2023)”
  • Seven named “Dispatchable Generation Resources that have decommissioned since December 1, 2020”.

Final Comments

ERCOT is serious about avoiding any repeats of the grid problems encountered in winter storms Uri and Elliott. Every available tool is being used to secure the necessary backup generation. Much of the generation named by ERCOT as qualified under their latest RFP is generation units that were recently retired, many because they could not compete with the artificially low prices that heavily subsidized wind and solar can offer, so they are still operational.

A better approach to the complex and expensive efforts ERCOT is going through would be for wind and solar generators to provide their own backup, enabling them to bid fairly with natural gas-fired generation. This approach would increase the value of wind and solar generation and reduce the burden placed on ERCOT to accommodate their unreliability. It would also reveal the actual levelized cost of wind and solar as being one of the most expensive forms of power generation. This approach would take the cost and operational burden off ERCOT and transfer it back to the generators where it belongs.


  1. John W. Garrett  

    I did not volunteer to be a guinea pig in a laboratory experiment being conducted by the gullible, credulous, innumerate, economic and scientific illiterates who have swallowed the evidence-light “Catastrophic/dangerous, CO2-driven anthropogenic global warming/climate change” CONJECTURE.


  2. Joanna Friebele  

    I agree with you whole heartily about wind and solar having their own backup – but the batteries they prefer are pretty much worthless, as you know. What would be your other solutions? With over 600 new battery projects on the ERCOT GIS list it seems to be the way they are going. So more subsidies and more tax breaks. Always in the taxpayers pocket making the playing field very tricky terrain for everyone else and more expensive for the ratepayer.
    There were some bills this session that were aimed at wrist smacking for unreliably, but I don’t know if they passed, that’s one way to do it. The constitutional amendment Prop 7 is another way – but I’m not sure that setting up a fund outside of general revenue is a good thing either.
    I like that ERCOT has moved forward now to protect the safety of the state, this will be cheaper in the long run than paying curtailment monies to Bitcoin etc., to cut back – and then you are at their mercy!
    I also don’t want to see wind and solar expand further – adding to the problem and then needing transmission – back to the taxpayers pocket!
    Thanks for your clear and concise article.


  3. Ed Ireland  

    Well said, John.



  4. Ed Ireland  

    Thank you for your thoughts and comments, Joanna. I appreciate hearing that you agree with my position that wind and solar should provide their own backup. One reason for that proposal is that it makes no sense at all for ERCOT to be doing the hard and expensive work of dealing with the intermittency problem of wind and solar.

    Another reason is that a more stable wind and solar/battery backup product offered to the grid would be more valuable to the wind and solar producers as well as to ERCOT. I say this because I don’t think that standalone battery storage works economically. A friend of mine in the Texas power business is trying out battery storage, and he says that the numbers don’t work most of the time, in part because the time spent charging the batteries is uncompensated downtime.

    Prop 7 is a type of capacity payment that gets ERCOT around the notion that they are a “power-only market.” That State Energy Fund is a bit of fighting fire with fire notion to counter the federal subsidies for wind and solar. On the subject of capacity payments, I noted in my current Substack article that ERCOT is admitting that they are buying capacity in their current effort to get retired coal plants back online ((1) Texas vows to fight EPA’s plans to kill coal-fired power generation ‘all the way to the Supreme Court’ (substack.com).

    The problem this is trying to deal with is the massive federal wind and solar subsidies distorting the power market. Overall, I think ERCOT is doing a good job of thinking outside the box.

    Thanks again for your comments and support.



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