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Tort Winter

Tort Winter


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We start by preparing the meringue. Whisk the egg whites with the lemon juice and the powdered sugar added gradually until a hard foam is obtained. ) and sprinkle with raisins. Bake at 100 degrees for about 3 and a half hours. In the last hour and a half I baked at 80 degrees (electric oven). Bake in gas ovens at 80 degrees with the oven door ajar ( put the tail of a wooden spoon on the door). After the meringue is ready, take it from the baking paper and leave it to cool.

I was preparing the countertops. I have to mention that for the second countertop I had to redo the quantities because I didn't have enough composition left ... but let's start ..

Mix the egg very well with the egg whites and sugar until it bubbles. Add oil and orange juice, then flour mixed with baking powder. Divide the composition into 2 equal parts (here I missed .. and I did not have enough for the second countertop ) .. bake 2 worktops in the tray in which I put baking paper, at 180 degrees for 8-10min. Then let them cool.

creams..first time we prepare chocolate cream.We start by putting hydrated gelatin in 50ml of water.Leave 10min time in which ... break the chocolate pieces and put it to melt on low heat together with 150ml liquid whipped cream.Do not boil, always stir until the chocolate melts..take it off the heat..let it for 2-3 minutes then add the gelatin. Stir to mix well. Beat the rest of the whipped cream and then mix it with the chocolate.

We put the cake top on a plate. We mount a detachable cake ring around it. We spread the chocolate cream and let it cool until we prepare the cream2.

Grate the oranges on a small grater and then clean them. We hydrate the gelatin in 100ml of water. We clean the core of the oranges from the skins and cut it into cubes. put in the citrus juice, on a steam bath or over low heat until the gelatin melts (without boiling) .. then add it to the cream cheese and mix.

We take the cake out of the fridge, we take the ring around it, we put the 2nd orange cream countertop. We dress it on the sides with this cream and then we put the meringue on top. I left him overnight.



Chocolate & # 8220Ladies Caprice & # 8221

  • Flour & # 8211 450 grams
  • Chicken egg & # 8211 5 pcs
  • Baking soda (baking soda) & # 8211 1 teaspoon
  • Whole milk & # 8211 1.5 cups
  • Sugar & # 8211 5 tbsp
  • Natural honey & # 8211 2.5 tbsp
  • Cocoa powder & # 8211 3.5 tbsp
  • Vanillin or vanilla sugar & # 8211 1 bag
  • Butter & # 8211 3.5 tbsp
  • Potato or corn starch & # 8211 3 tbsp
  • Water & # 8211 6 tbsp.

Evaluate the classic cake recipe & # 8220Bird & # 8217s Milk & # 8221 at home is not so difficult to prepare.

Remember the taste of childhood, chocolate and delicate cake & # 8220Prague & # 8221, prepare it according to our recipe with photos and tips from chefs.

A simple recipe for the cake & # 8220Smetannik & # 8221 with step by step photos. See, learn and cook.

Put honey, 4 eggs, soda, 2.5 tablespoons of cocoa in an iron bowl, mix well and keep in a water bath until you get a brown mixture.

Remove from heat, allow to cool and in small portions add sifted flour. When the dough starts to thicken, place it on a flat surface and start kneading. When it becomes plastic, we wrap it in a disposable bag and put it in the refrigerator door for 40 minutes.

Meanwhile, prepare the cream. Pour the milk into a deeply glazed container, add two tablespoons of flour, starch, vanilla and an egg. We put a small ring and continue to mix.

As soon as the mass begins to thicken, turn off the gas, add 2.5 tablespoons of oil and after kneading completely, let it cool completely.

Remove the cake batter and divide it into 6 equal mass parts. Place cakes and bake in the oven on a baking sheet at a temperature of 190 ° & # 8211 195 ° C (10 & # 8211 13 minutes for each cake).

Pour the water into an enamel bowl, 0.5 cups of milk and add a tablespoon of cocoa. Stir and set over low heat. The heating is cooked in 5 & # 8211 7 minutes. At the end of the process add a tablespoon of butter.

We finish the cakes richly finished with cream, pour over the icing on top and let it soak in & # 8220Lady's whim & # 8221 for 6-7 hours.

The ingredients for cakes and creams are different in both recipes. If desired, they can be combined at their discretion & # 8211 the result of any variations will be delicious.


Easter Cake: 5 of the most delicious and simple recipes

All housewives are divided into two groups: those who do not agree to sleep at night and enthusiastically kneading the dough for cakes, and those who are too lazy once, not-able, and reach for festive cakes in the store. Of course, the Easter cake at home is much more delicious than the one purchased. However, sometimes, looking at the list of complex products and processes for converting these lists into a thick fragrant crust, many hands go down. Baking bread, especially according to traditional recipes, is not given to everyone. Therefore, simplified recipes have been invented for Easter cakes, which use dry yeast and much less muffins.


Easter cake
Easter cake for Easter
Easter cake with raisins
Easter with candied fruit sequins
Lemon cake
Easter cake & laquoPoppy & raquo

There are, to help the 5 most delicious and easy recipes, you just need self-confidence and a positive attitude, not without reason, in the old saying & bdquoWhat is the mood - and a cake & ldquo.

About how to prepare for cooking cakes, our site wrote several times. In the current review there will be only recipes, and they will be more than simple. Of course, in the "quick" dough for cakes, do not put too much muffin as in the one prepared almost overnight. However, you can soak raisins and dried cherries in rum or brandy. Add instead of the usual mixture of vanilla cardamom, nutmeg and cloves, so that the aroma surrounding the head, you can. If you're more familiar with vanilla flavor, buy real vanilla valves - you'll understand the difference between store chemistry and real fragrant vanilla. Do not replace real butter with margarine. Buy chicken eggs at home. Take baking bread seriously, because you cook once a year.

So, you have decided to bake the Easter cake, and the 5 most delicious and simple recipes are waiting for you in hot pens!

Bright Easter Kulichi

ingredient:
For the test:
500 ml of milk,
1-1.3 kg of flour,
6 eggs,
200 g butter,
200-250 g of sugar,
11 g dry yeast,
& frac12 h. l. vanillin,
1 pinch of salt,
300 grams of seedless raisins.
For the glaze:
2 egg whites,
100 g of sugar.
For decoration:
colored marmalade or sprinkling.

Method of preparation:
Dilute the dry yeast in warm milk, add 500 g of flour and put the spoon in a warm place for half an hour. Separate the egg yolks from the protein and rub with sugar and vanilla. Peel a squash, grate it and squeeze the salt. In the approaching eyes, enter the yolks, soften the butter, proteins and, gradually, stirring, pour the remaining flour. Knead the dough and leave it for an hour. Then add the washed raisins, stir and wait until the dough rises again. Fill the filled molds with oily molds and leave in this state for a period of time so that the dough rises and fills the molds. Bake the cakes in the preheated to 150 & ordmFrom the oven to the preparation. Meanwhile, prepare the icing. To do this, mix the proteins with the sugar until stable peaks form. The hot cakes are covered with cooked icing and decorated with colorful pieces of marmalade, chopped nuts or ready-to-buy powder.

"Brave" Easter Cake

ingredient:
For the test:
1 kg of flour,
2 tablespoons. warm milk,
250 g of margarine,
6 eggs,
1 tbsp. sugar,
1 teaspoon. vanillin,
2 tablespoons. l. dry yeast,
1 tbsp. Peeled pumpkin seeds.
For the glaze:
1 protein,
& frac12 Art. sugar,
1 teaspoon. lemon juice,
1 pinch of salt.
For decoration:
100 g of colorful colored fruits.

Method of preparation:
For opaids, mix the dry yeast with 1 teaspoon. sugar, pour in milk, mix and add 1.5 tbsp. flour. Leave the sponge in a warm place for 1 hour. With eggs, separate the egg yolks from the protein. Mix the egg yolks with the remaining sugar and vanilla, add 200 g of soft margarine and mix. There, the total mass is poured into the spit. Pour the white into a foam and handle the dough. Gradually pass the remaining flour into it. Then add the pumpkin seeds (whole or chopped), mix well and leave the dough for another hour in a warm place. Ready to bake the molds, the remaining margarine oil and fill them with half a dough. Let the dough rise and only then put the mold in the preheated to 180 & ordmFrom the oven. Bake for an hour. Push the strong protein with a pinch of salt. Do not stop the whip, add lemon juice and sugar. Pour the resulting icing over hot cakes, sprinkle with candied fruit and leave the icing to freeze.

IT

"Catherine" Easter Cake

ingredient:
500 ml of warm milk,
9-10 tablespoons. flour,
1 tbsp. sugar,
1 teaspoon. salt,
& frac12 Art. vegetable refining oil.
200 g butter or margarine,
5 eggs,
2 teaspoons. dry yeast,
& frac12 Art. raisins without holes.

Method of preparation:
In a 0.5 liter jar pour a little warm milk, add 2 teaspoons. sugar and yeast, mix and put the spoon in a warm place so that it rises. In a large capacity, sieve flour, but not all, but about 8 glasses. In a separate bowl, dilute in milk separately eggs, salt, vegetables and butter, which are grown with sugar. Pour the mixture into the sifted flour, then - the spoon and add the raisins. Knead the dough, gradually adding the rest of the flour. The test that you will get a lot, will be enough to prepare a few cakes. Spread the dough in the form of oil and bake in a preheated oven at 180 ° C & ordm From the oven to the preparation. Cool the crumbly cakes, pour the icing, prepare from 1 protein and 1 tbsp. sugar, beaten with a mixer, Decorate cakes at will.

And cakes to get really correct, you can try and & bdquonoapte & ldquo recipes this way, the yeast, even dry, will be able to pick up more baking in the test, which means that Easter cakes will be the most delicious.

ingredient:
For the test:
3 tablespoons. flour,
1 tbsp. warm milk,
200 g butter,
1 tbsp. sugar,
2 eggs,
2 teaspoons. dry yeast,
& frac12 Art. raisins,
Vanillin - the taste.
For the glaze:
3 proteins,
1 tbsp. sugar.

Method of preparation:
In the evening in a saucepan enamel, place, without stirring, yeast, sliced ​​butter, sugar (sweet tooth can increase the amount of sugar added to the sugar mentioned in the recipe glass by half more) and wash the raisins. As for the latter, I want to give you advice: take dark raisins for this batch. When infused overnight, the dough will turn out to be a very pleasant cream color. Pour everything with a glass of warm milk, cover with a clean towel and leave until morning. In the morning, the taste of flour and vanilla is added to this meal. Knead the dough and put it in the form of oil, filling half of it. Let the dough rise until it doubles in size. Now put the cake in the oven and bake at 200 & ordmFrom preparation. From time to time, check the baking with a wooden stick. Finished the Easter cake with icing, decorate it with a press and dry in an open oven.

"Glorious" Easter cake with saffron

ingredient:
7.5 tablespoons. flour,
1.5 tablespoons. milk,
1.5 tablespoons. sugar,
1.5 tablespoons. melted butter,
8 eggs,
1.5 bags of dry yeast,
vanilla - for taste,
2 tablespoons. l. Dried saffron diluted in a small amount of water,
0.5 tablespoons. raisins.

Method of preparation:
Push the eggs with the sugar, add the melted butter, milk, spices and flour mixed with dry yeast in the mixture. Place the mixture overnight in a warm place. During this time, couple the twisted dough several times. It should not turn out to be steep. Forms for baking oil, sprinkled with wheat or breadcrumbs. Fill out the forms with a test on ⅓ and let it rise slightly. Bake the cakes in the preheated to 180-200 & ordmFrom the oven to the ready, checking it with a wooden stick or a ray. The prepared cakes are sprinkled with powdered sugar and decorated at your discretion.


What if There are Criminal Charges Involved?

There are not usually criminal charges involved in personal injury claims, but it & # 8217s not so rare that it shouldn & # 8217t not be mentioned. For example, if one person is assaulted by another, there would be criminal charges, and those would be processed by the state. It would not be John Jones v. Stephanie Miss. It would be Florida v. Stephanie Miss. Those criminal charges won’t result in anything for you as the victim.

But, you can take your own tort claim to the civil court and pursue compensation to cover your injuries and other damages.


What are the Most Common Personal Injury Claims in Florida?

Slip and fall accidents, dog bites, product liability, auto accidents, worker’s comp, and medical malpractice are always the top areas in personal injuries. These accidents cover the widest opportunities for injuries, and it can be relatively easy to move a case forward with these. Animal attacks perhaps pose the biggest struggle. Unlike other states, however, it does not have a one-bite rule, which often makes these cases more complex.

In Florida, dog bites and other damages from animals are the responsibility of the animal owner even if the attack happened on private property as long as their presence was lawful.


Diplomat cake

Hello! they are novices, what do they do with egg white cream. to mix with egg yolk cream and whipped cream? Thanks!

Hi, it's a small mistake, don't put the egg whites in the cream (only the yolks). So make a single cream of yolks and sugar, add milk and boil on a steam bath, then mix with whipped cream and gelatin (plus vanilla essence).

Thank you, keep up the good work, I'm delighted with the ideas and recipes!

HOW DO I PUT GELATINE IN CAKE, CREAM OR CREAM TO STRENGTHEN BEAUTIFULLY? I PUT THE GELATIN IN WARM WATER AND AFTER I PUT IT IN THE CREAM, IT COOKED. I USED 2 GELATINE ENVELOPES -KNOXORIGINAL, UNFLAVORED. HELP US HOW TO PREVENT COOLINGS! IT WAS WRONG WHEN I FOUND CREATED PIECES OF GELATINE IN CREAM. I DIDN'T DISSOLVE IT, I DIDN'T ADD IT WELL TO THE CREAM. THANK YOU.

With pleasure, but you really don't need so many thanks. It goes up to my head :)

It looks insane :), I will definitely try it.

With the appearance I see that I convinced you, now it remains to be seen how you will like the taste of the diplomat cake: D

Mmmmmmmmmm like, it looks fffffffff good, it's pleasing to the eye and exciting for the papillae, dear R: d.
Delighted, as with every post of yours.

Diana, I think we have a reciprocal relationship here :)) And I always love your comments)

Maybe you can post some recipes for caltabosi, sausages, something specific to the month. that also through your recipes I will find something special !! That if you have.

I'm a little comfortable to do something like that, so I don't promise anything :) Although now it seems to me that the idea of ​​making a few sausages makes me smile.

I tried too but it didn't work out. For one reason or another, my egg cream with bain-marie sugar did not harden. I beat the eggs well with sugar for about a quarter of an hour, I put milk, but when I put the cream (egg with milk) on the steam, its composition did not change at all (it remained as liquid). And I thought I should and I mixed the cream with whipped cream and gelatin. But from this mixture the cream (egg with milk) remained at the bottom of the bowl and the whipped cream rose to the surface. Can you tell me why? Va roooog. : o3

Yes, I can :) Unfortunately, you didn't boil the cake cream enough. I even mentioned in the recipe that after about 15 minutes of cooking the bain-marie cream will have to have thickened a little, but it seems that you missed it. It still happens, but don't forget that small details can make a difference - next time you will surely make the diplomat cake without any problems.

And if it takes more than 15 minutes to harden, what do I do?

You're not doing anything, Alex. Leave the cream on the fire until you notice that it starts to thicken. The 15 minutes are indicative, we don't have to take it only after time - my electric hob heats up in one way, the stove in another way (even the gas pressure sometimes differs, especially in the winter months).

I also made the recipe ... about two weeks ago. I had the same problem with that cream of yolk + sugar + milk. I may fall asleep next to the stove until it starts to thicken. but G E N I A L came out! Tastes and easy.

I have always admired men who know and like to cook

Unfortunately, I'm not really admirable. I like to cook, but I don't know how to do it as well as I would like :)

you are modest, and I admire the men who cook, I would have liked k and my husband to cook but unfortunately he doesn't even make french fries

I try to be realistic, especially knowing that I don't actually cook as often as people think. And then you know how it is. If I stay in the kitchen, then I don't have time to do other household things that your husband probably does :)

I made it and it turned out delicious. I received praise from everyone :)) thanks for the recipe :)

You really don't have to, the praise received is only your merit)

Beautiful presentations, attractive blog! : D

I like your recipes, but please don't have any recipes without fats or fried foods.

There aren't many of them, but there are already dozens of good recipes without fat or fried on the blog. The difficult part is finding them, thinking that they are mixed among hundreds of other recipes, but you will surely discover them. :)

I also tried the cake, but I don't know why the yolks + sugar + milk didn't set at all. I kept them on the water bath for half an hour, but nothing. I do not understand why. I also tried a cream for another cake where I had to mix eggs + sugar DIRECTLY on the fire until it thickens - although I kept them DIRECTLY on the fire for 45 minutes, they didn't thicken. I'm wodering why?

Not being next to you to see exactly how you did it, you realize that it's hard for me to tell you why they didn't come together. But clearly something is wrong, because even a child knows that the egg coagulates if it is kept on fire :) And you say that you suffered it twice, the second time even keeping them DIRECTLY on the fire . I really don't know what to say. but some more experienced reader may "enlighten" us.

the recipe lacks starch or flour for the cream. yolk + sugar + milk become & vanilla quotsos & quot, not cream, regardless of the amount of gelatin that is added after.

Fortunately, the recipe images show how & quotgalbenus + sugar + milk & quot become & vanilla quotsos & quot only initially, and after they are cooked, combined with gelatin and stay in the fridge for a while they harden (and the image with the recipe ingredients does not show any flour). If I had made a "thick cream" with flour for the diplomat cake, then what was the point of gelatin. As the cream was "thick", it would probably have thickened even more if it had been kept in the fridge long enough. Finally, it's just an unverified presumption personally (it may not be strong enough to resemble the diplomat we know), which is why those without much experience in the kitchen (as I admit I am), they should follow exactly the above recipe, and if the gelatin is not expired or boiled too much, then the diplomat cake should come out perfectly.

I also made the cake, the first attempt failed because I probably mixed the hot cream with the whipped cream. So I threw everything away and started over. In the end, a super, good-looking and delicious cake came out.
Now I make the experienced and I ENLIGHTEN Mrs. Anonymous. I think he forgot to turn on the stove. I have no other explanation.

Roxana, I know it's not nice to laugh at someone else's trouble / failure, but there's no point in being hypocritical and not admitting that I had fun reading your comment.
I try to explain the recipes in as much detail as possible and to emphasize certain details that seem more important to me, precisely so that anyone - even those without experience in the kitchen - can successfully prepare that recipe. Even then, if someone is having problems, I try to help them and find out the cause together (because, in most cases, I noticed that the recipe is read diagonally or not enough attention is paid to the details - how it seems you have suffered it too with the first attempt at a diploma cake: P). But, in the case above, I really felt a little confused.


How to make red wine torrijas

There is no doubt that red wine torrijas stand out because it is as traditional a recipe as it is popular, which grandmothers used to make for their grandchildren on cold winter evenings. Do you want to learn how to prepare them? Take note It will only take 15 minutes to prepare and another 15 minutes to cook.

  • 1 piece of bread something heavy
  • 1 glass of red wine
  • 1 glass of water
  • 60 gr. of sugar
  • 4 eggs
  • Extra virgin olive oil
  • sugar
  • Cinnamon powder

Preparation of red wine toast:

We must first evaporate the alcohol present in the red wine and combine it with the sugar to obtain a delicious sweet infusion. To do this, put the sugar, water and red wine in a saucepan and heat the heat until it starts to boil, letting it simmer over medium heat for 5 minutes. After this time, set the fire aside and let the wine infusion cool slightly.

Cut slices of bread leaving each slice about 1 cm thick. Put them little by little in a well. Then pour over the sweet infusion of red wine, leaving slices of bread well soaked.

Put extra virgin olive oil in a pan.

In a bowl, beat all the eggs well. Now pass slices of bread soaked in wine for the freshly beaten egg. Fry each slice in hot olive oil on each side until golden brown.

Remove each slice of bread from the tray and leave them on paper towels to filter a little oil.

In a bowl, mix some sugar with cinnamon powder and before the French toast go over this mixture. READY! to enjoy


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Best ever chocolate brownies recipe

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Spiced carrot & # 038 lentil soup

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Ultimate chocolate cake

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Spicy root & # 038 lentil casserole

The potatoes in this recipe take on the spicy flavors beautifully - our idea of ​​the perfect veggie supper

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Delight friends with an afternoon tea that includes this easy carrot cake. You can bake the cake, freeze it and just drizzle over the icing on the day

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Classic scones with jam & # 038 clotted cream

You can have a batch of scones on the table in 20 minutes with Jane Hornby's storecupboard recipe, perfect for unexpected guests

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A healthy burger that's filling too. These are great for anyone after a satisfying bite low in calories.


Viewpoint: Subrogating Freeze Damage When Texas Power Plants Are Not Dressed For Winter

Successful subrogation against power companies is not a given. In determining whether the Electric Reliability Council of Texas (ERCOT) may be sued for its clear negligence in failing to properly winterize power production facilities and the power grid that it runs in Texas, the issue is currently in limbo. The Texas Supreme Court is currently reviewing whether ERCOT will be granted governmental immunity.

There are a myriad of reasons Texas has seen power outages, but many of the failures are likely tied to simply being unprepared for extreme cold weather. In Texas, power is generated from natural gas, coal, nuclear, and wind. This is not unsimilar to power generation in states that inhibit colder climates. It is clear that all of this equipment has the capability to be winterized and made to operate in sub-freezing temperatures. The issue is that the power providers in Texas have not undertaken the time and investment necessary to properly winterize their equipment.

The Federal Energy Regulatory Commission (& # 8220FERC & # 8221) and the North America Electric Reliability Corporation (& # 8220NERC & # 8221) warned Texas a decade ago that its power plants couldn & # 8217t not be counted on to reliably churn out electricity in bitterly cold conditions , when the last deep freeze in Texas plunged four million people into the dark. The FERC and the NERC had both recommended that utilities use more insulation, heat pipes, and take other steps to winterize plants & # 8212 strategies commonly observed in cooler climates but not in normally warmer weather climates such as Texas.

Mark Solomon

ERCOT clearly mishandled the winter storm that rolled through Texas over the past week. ERCOT & # 8217s failures left millions of Texas residents without power and without heat for days in below-freezing temperatures.

On February 16, 2021, Governor Greg Abbott declared the reform of ERCOT an emergency item this legislative session. In declaring this item an emergency, the Governor is calling on the legislature to investigate ERCOT and ensure Texans never again experience power outages on the scale they saw last week.

Governor Abbot stated that & # 8220Far too many Texans are without power and heat for their homes as our state faces freezing temperatures and severe winter weather. This is unacceptable. Reviewing the preparations and decisions by ERCOT is an emergency item so we can get a full picture of what caused this problem and find long-term solutions. I thank my partners in the House and Senate for acting quickly on this challenge, and I will work with them to enhance Texas & # 8217 electric grid and ensure that our state never experiences power outages like this again. & # 8221

As noted above, the Texas Supreme Court will be reviewing whether or not ERCOT will be given governmental immunity. ERCOT is the agency tasked with management of the state & # 8217s primary electric grid. ERCOT operates under a quasi-governmental fashion. ERCOT has some of its responsibilities set forth in Texas law and also has a board of directors that answers directly to the Texas Public Utility Commission, a state agency.

ERCOT was sued by a company alleging that it improperly manipulated projections of the state & # 8217s future power needs after coming under political pressure to encourage new power plant construction. ERCOT raised the affirmative defense of sovereign immunity. An appeals court agreed with this position and the case has been appealed to the Texas Supreme Court to decide.

The Dallas Court of Appeals ultimately held that (1) ERCOT is a private corporation exercising power delegated to it by an administrative agency pursuant to legislation (2) ERCOT & # 8217s power includes rulemaking authority that is binding on market participants and (3) ERCOT is subject to broad oversight by the Public Utilities Commission (& # 8220PUC & # 8221), which can decertify it. Based on the reasoning of the SRO immunity cases described above and the & # 8220nature and purposes & # 8221 of sovereign immunity, the court of appeals concluded ERCOT is entitled to sovereign immunity from private damages suits in connection with the discharge of its regulatory responsibilities. Electric Reliability Council of Texas, Inc. v. Panda Power Generation Infrastructure Fund, LLC, 552 S.W.3d 297 (Tex. App. - Dallas 2018).

If ERCOT is deemed to have sovereign immunity, they will be protected from tort liability for their actions leading up to the power outages that affected millions and led to what will ultimately be damages in the hundreds of millions of dollars from burst pipes and the subsequent property damages. If not, ERCOT will be able to be sued just like any other corporation. Given that they operate in a quasi-governmental capacity, ERCOT & # 8217s status as a governmental entity entitled to tort immunity will rest solely in the hands of the Texas Supreme Court.

This is likely to be a difficult task. The Texas PUC controls ERCOT & # 8217s funding, budget, operations, discipline, and governance. Nothing ERCOT does today is free from the state & # 8217s direct oversight. The Texas PUC has vast authority over ERCOT. ERCOT is essentially doing the State of Texas & # 8217 work with the state & # 8217s money and under the state & # 8217s supervision and regulation.

The liability for governmental units is controlled by the Texas Tort Claims Act, which is addressed in Chapter 101 of the Texas Civil Practice & Remedies Code. The specific section spelling out the limited circumstances when the government can be held liable is as follows:

Sec. 101.021. GOVERNMENTAL LIABILITY. A governmental unit in the state is liable for:

(1) property damage, personal injury, and death proximately caused by the wrongful act or omission or the negligence of an employee acting within his scope of employment if:

(A) the property damage, personal injury, or death arises from the operation or use of a motor-driven vehicle or motor-driven equipment and

(B) the employee would be personally liable to the claimant according to Texas law and

(2) personal injury and death so caused by a condition or use of tangible personal or real property if the governmental unit would, were it a private person, be liable to the claimant according to Texas law.

The Texas Tort Claims Act does not create new legal duties it only waives governmental immunity in circumstances where a private person similarly situated would be liable. In order to establish tort liability, a plaintiff must prove the existence and violation of a legal duty owed to him by the defendant. The existence of a legal duty is a question of law for the court although in some instances it may require the resolution of disputed facts or inferences which are inappropriate for legal resolution. Fort Bend County Drainage Dist. v. Sbrusch, 818 S.W.2d 392 (Tex. 1991).

Certain public utilities, e.g., electric utilities, are considered proprietary functions and their activities may not be entitled to immunity under the Tort Claims Act. However, this typically applies to municipalities. ERCOT is not a municipality.

It should be noted that under the Texas Tort Claims Act, notice must be given within six months after the date of the incident. See Tex. Civ. Prac. Rem. Code § 101.101. The notice must reasonably describe: (1) the damage or injury claimed (2) the time and place of the incident and (3) the incident.

The potential exposure from the losses sustained by property owners as a result of the power outages will be in the hundreds of millions of dollars. The ruling of the Texas Supreme Court will have overreaching implications for the residents of Texas and the insurance companies who cover those citizens. A favorable ruling will open the door for subrogation claims to proceed forward. An unfavorable ruling will shut that door completely. Given the six-month notice requirement, companies will need to act fast in putting ERCOT on notice of their claims, so as to protect any potential right they might have in the future.

Another obstacle which must be navigated is the existence of subrogation-killing tariffs which contain limitations of liability. Electric utilities in Texas, as they do elsewhere, operate pursuant to publicly filed tariffs. Texas is unique because for the last 22 years, it has operated under a system of deregulation. Control of the entire state’s power generation and delivery system is given to a market-based assemblage of private generators, transmission companies, and energy retailers. This frontier system of power distribution resulted in cheaper power for Texas residents but it also apparently allowed the energy catastrophe of last week. There was little incentive and no oversight of investing in weather protection or maintenance. A winter event like the one just experienced was not planned for. Tariffs often limit liability for negligence, but retain liability for gross negligence and/or willful misconduct. These obstacles will create interesting subrogation challenges for the many property subrogation claims which are already being referred to MWL.


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